East Link Extension FHWA Record of Decision

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Table of Contents

Decision ...... i

East Link Light Rail Transit Project ...... 4

Final Environmental Impact Statement Issued ...... 4

Background and Process ...... 5

Project Purpose and Need ...... 6

Selected Alternative ...... 6

No Build Alternative ...... 7

Interstate 90 Alternative (A1) ...... 8

112th Avenue SE Modified Alternative (B2M) ...... 8

110th NE Tunnel Alternative (C9T) ...... 9

Basis for FHWA Decisions ...... 9

Interstate 90 ...... 10

Operations ...... 10

Construction ...... 11

Environmental Benefits or Impacts ...... 11

Interstate 405 ...... 12

Operations and Safety ...... 12

East Link Project FHWA Record of Decision November2011

Construction ...... 13

Section 4(f) ...... 13

Measures to Minimize Harm ...... 13

Highway Operations and Safety Mitigation Measures ...... 13

Intersection Level of Service ...... 13

Traffic During Construction ...... 14

Freight Mobility and Access Mitigation Measures ...... 14

Navigable Waterways Mitigation Measures ...... 15

Air Quality and Greenhouse Gases ...... 15

Noise and Vibration ...... 16

Ecosystem Resources ...... 18

Geology and Soils ...... 19

Electromagnetic Fields ...... 19

Public Services ...... 19

Utilities ...... 19

Parkland and Open Space ...... 19

Determinations and Findings ...... 20

Comments on the East Link Final EIS and Responses ...... 20

Attachment A: Map of the Selected Alternative ...... 24

East Link Project FHWA Record of Decision November2011

Attachment B: Maps of the Alternatives Analyzed in the Final EIS ...... 25

Attachment C: Comments Received on the Final EIS and Responses ...... 26

East Link Project FHWA Record of Decision November2011

East Link Light Rail Transit Project

The East Link Project is an extension of the Link light rail system providing urban transportation improvements in the Central Puget Sound metropolitan region. The East Link project would connect to the existing light rail system in downtown Seattle and extend the system east to Mercer Island, Bellevue, and Redmond. The project is divided into five geographic segments over an approximately 18‐mile corridor. Segment A, Interstate 90, connects downtown Seattle to Mercer Island and South Bellevue via I‐90. Segment B, South Bellevue, connects I‐90 to downtown Bellevue along Bellevue Way SE and 112th Avenue SE. Segment C, Downtown Bellevue, travels at a tunnel profile through downtown Bellevue and an elevated I‐405 crossing at NE 6th Street. Segment D, Bel‐Red/Overlake, would travel from the Bel‐Red Subarea east of I‐405 to the Overlake Transit Center, along the Bel‐Red corridor. Segment E, Downtown Redmond, would travel from Overlake Transit Center to Downtown Redmond via the SR 520 corridor and then proceed to Downtown Redmond via the former BNSF Railway corridor. Please see Attachment A: Map of Selected Alternative.

Final Environmental Impact Statement Issued

The East Link Project is described in the final environmental impact statement (FEIS), approved by the Federal Transit Administration on June 15, 2011 and issued on July 15, 2011. FHWA served as a cooperating agency on the EIS and provided input during its development, including extensive written comments that were submitted on the DEIS. FHWA has conducted an independent review of the FEIS and concluded that our comments have been satisfied. Pursuant to 40 CFR 1506.3, FHWA hereby adopts the East Link FEIS as it relates to the FHWA’s decisions, which are detailed below. The FEIS Notice of Availability appeared in the Federal Register on July 15, 2011.

The Federal Transit Administration (FTA), as the federal lead agency, completed its Record of Decision for the Central Puget Sound Regional Transit Authority’s (Sound Transit) East Link Light Rail Transit Project on November 16, 2011. FTA’s Record of Decision selected the preferred alternative for the construction and operation of the East Link Light Rail Project. The Federal Highway Administration (FHWA), as a cooperating agency under NEPA, has completed this Record of Decision for elements of the project affecting FHWA right‐of‐way and requiring FHWA approvals. East Link Project elements will affect portions of I‐90 in Seattle, Mercer Island, and Bellevue, Washington and portions of I‐405 in Bellevue, Washington.

Federal Highway Administration approvals that will be required for East Link include:

 Breaks‐in‐access, including those determined necessary during the design process as well as those requested during Construction  Operations and Maintenance Agreement, related to the airspace lease  Approval of conversion of highway lanes to high capacity transit  Approval of bridge expansion joint design

Background and Process

Local, regional, and state agencies have been studying high‐capacity transportation alternatives to connect Seattle with the Eastside of King County since the mid‐1960s. The history and outcomes of these plans, studies, and public involvement processes is summarized in Section 1.3 of the Final EIS and fully described in the report titled East Corridor High‐Capacity Transit Mode Analysis History (Sound Transit, 2006). This history forms the basis for the Purpose and Need statement for the East Link Project EIS.

Consistent 23 CFR Part 450, FTA’s decision process was based on comprehensive studies that were completed in cooperation with state and local agencies and broad public input. In particular, the Sound Transit Board and FTA made the following two major decisions after extensive evaluation and review with other agencies and the public before beginning this East Link Project EIS:

 Regional High‐Capacity Transit (HCT) to the Eastside via I–90 is necessary.  Light rail is the preferred HCT technology for the I–90/East Corridor connecting Seattle, Mercer Island, Bellevue, Overlake, and Redmond.

Sound Transit and the FTA, as federal lead agency, initiated the East Link Project NEPA process by publishing a Notice of Intent (NOI) in the Federal Register on August 22, 2006. The environmental scoping process was conducted in September 2006, which included extensive community outreach, formal scoping meetings, and public hearings to solicit public input on the project purpose and need, alternative alignments, profiles, and station locations for detailed analysis in the Environmental Impact Statement (EIS). In November 2008, the Sound Transit 2 (ST2) plan was approved by voters. ST2 is the next phase of mass transit improvements in the Puget Sound region, and includes the East Link Project. The Draft EIS was issued on December 12, 2008. On May 14, 2009, following review of the Draft EIS, and after consideration of public and agency comments received, and other information, the Sound Transit Board identified preferred light rail routes and station locations for inclusion in the East Link Final EIS. In response to public and agency comments, the Sound Transit Board directed staff to evaluate more design options in downtown Bellevue and subsequently modified the preferred light‐rail routes and station locations. A Supplemental Draft EIS that analyzed the modifications was issued on November 12, 2010. After the publication of the Final EIS on July 15, 2011, the Sound Transit Board selected the project to be built on July 28, 2011. The Federal Transit Administration identified the Locally Preferred

East Link Project FHWA Record of Decision November2011

Alternative (LPA) in its Record of Decision, consistent with the Sound Transit Board’s selection of the alignment and stations to be built.

Project Purpose and Need

The purpose of the East Link Project is to expand the Sound Transit Link light rail system from Seattle to Mercer Island, Bellevue and Redmond via Interstate 90 (I‐90) and to provide a reliable and efficient alternative for moving people throughout the region.

Current and projected population and employment trends reveal a need to provide light rail transit between Seattle and the Bellevue and Redmond urban centers. Existing transit will not be able to serve the future transit needs in the project corridor for the following reasons:

 Increased demand for transit services across Lake Washington is expected to double by 2030 as a result of residential and employment growth on both sides of Lake Washington.  Regional urban center growth plans supported by HCT investments in accordance with Puget Sound Regional Council (PSRC)’s adopted Transportation 2040.  Increased congestion on I‐90 will further limit transit performance as the I‐90 corridor reaches maximum vehicle capacity during peak‐hour travel as early as 2015 (WSDOT, 2006).  Operating deficiencies in regional bus transit service will continue to occur due to lower speeds and decreasing reliability.  Limited transit capacity and connectivity between the areas of highest employment density in the region will occur due to constraints of the current road system.

The East Link Project would meet the stated need by providing greater capacity and reliability and improving travel time for people traveling between Seattle, Mercer Island, Bellevue, and Redmond. To meet planned growth in the corridor, Bellevue, Seattle, and Redmond have made land use and planning decisions based upon increased employment and residential density, which would be more fully realized with an HCT connection across I‐90. East Link is this connection.

Selected Alternative

The alternative requiring FHWA approvals was designated as the preferred alternative in the FEIS and is selected as the Locally Preferred Alternative (LPA) in FTA’s Record of Decision:

Segment A: Interstate 90 Alternative (A1) (portions occurring within I‐90 FHWA ROW);

Segment B: 112th SE Modified Alternative (B2M) (portions occurring within I‐90 FHWA ROW); East Link Project FHWA Record of Decision November2011

Segment C: 110th NE Tunnel Alternative (C9T) (portions occurring within I‐405 FHWA ROW);

Segment D: NE 16th At‐Grade Alternative (D2A); and

Segment E: Marymoor Alternative (E2).

The portions of the selected alternative that will occur within FHWA right‐of‐way are limited to portions of Segment A (Alternative A1, in the I‐90 right‐of‐way); Segment B (Alternative B2M, exiting I‐90 right‐of‐ way at the Bellevue Way interchange); and Segment C (Alternative C9T, crossing I‐405). Alternatives for these segments, and the no‐build alternative, are described below with additional detail provided in the FEIS. See Exhibits B‐1 through B‐3 in Attachment B for a depiction of these alternatives. No portions of the selected alternative in Segments D (D2A) and E (E2) will occur within or affect FHWA right‐of‐way. The five maintenance facility locations analyzed in the Final EIS are all located in Segments D and E, and none would affect FHWA right‐of‐way.

No Build Alternative

The No Build Alternative represents the transportation system and environment as they would exist without the proposed project. For the transportation analysis in the East Link Project Final EIS for Segment A (I‐90), there are two No Build Alternatives related to implementing the various stages of the I‐90 Two‐Way Transit and HOV Operations Project. Stages 1 and 2 would place HOV lanes in the outer roadway, and build or improve HOV direct access ramps on I‐90 between Mercer Island and Bellevue. Stage 3 of the I‐90 Two‐Way Transit and HOV Operations Project would place HOV lanes in the outer roadway between Seattle and Mercer Island and improve HOV direct access on Mercer Island. At the time the transportation analysis methodology was established for the East Link EIS, funding for Stage 3 was uncertain. Therefore, one No Build Alternative includes construction and operation of Stages 1 and 2 only, while the other assumes a completed I‐90 Two‐Way Transit and HOV Operations Project (Stages 1 through 3), with HOV lanes in the outer roadway as well as the center roadway.

Under either of the above two No Build Alternative scenarios, increased roadway congestion into and out of urban centers would occur, even with planned local and regional roadway improvements. Vehicle travel times would increase, especially on I‐90, and in some cases double from today. This would limit the region’s mobility and constrain access between the designated Puget Sound urban centers. Many intersections adjacent to I‐90 and I‐405 would operate poorly and not meet standards. With this increase in congestion, public transit speeds would decrease by 30 percent from today and reduce transit’s reliability. This would limit the attractiveness of transit as a transportation option and potentially lead to lower overall transit ridership. Even so, projected residential and employment growth is expected to double transit ridership demand across Lake Washington and between Bellevue and

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Redmond by 2030 with the No Build Alternative, highlighting the importance of providing reliable transit service.

Interstate 90 Alternative (A1)

Interstate 90 Alternative (A1) crosses Lake Washington via I‐90 and connects with the Central Link Light Rail system at the International District/Chinatown Station. From there it enters I‐90 via the D2 Roadway (an exclusive access road for transit to the reversible center roadway of I‐90). It provides a station in the center of I‐90, between Rainier Avenue and 23rd Avenue, just east of the current I‐90 Rainier bus stop. The Rainier Station includes pedestrian connections to 23rd Avenue South and Rainier Avenue South. Alternative A1 continues in the I‐90 reversible center lanes, first crossing Lake Washington to a Mercer Island station between 77th and 80th Avenues, and then crossing the I‐90 East Channel Bridge to connect to Segment B in south Bellevue. Pedestrian access to the Mercer Island Station is via 80th Avenue SE and 77th Avenue SE. Alternative A1 includes an eastbound HOV direct‐access off‐ramp on Mercer Island at Island Crest Way.

The East Link Project would require the I‐90 center roadway to be dedicated to High Capacity Transit, as stipulated in the 1976 Memorandum Agreement (and as amended in 2004) by Seattle, Mercer Island, Bellevue, King County Metro, WSDOT, and Sound Transit. Today, the reversible center roadway is dedicated to peak‐direction HOV lanes, and the outer roadways are general‐purpose lanes. HOV lanes are being built on the outer roadways in a three‐stage project (the I‐90 Two‐Way Transit and HOV Project), thus allowing HOVs to travel in both directions any time of the day. The FHWA Record of Decision for the I‐90 Two‐Way Transit and HOV Project (September 2004) found that the Selected Alternative (Alternative R‐8A) was chosen in part because it “would accommodate the ultimate configuration of I‐90 (High Capacity Transit in the center lanes). Alternative R‐8A adds directional HOV lanes on the outer roadways which would provide for reliable transit and HOV operations with the ultimate roadway configuration.” The entire I‐90 Two‐Way Transit and HOV Operations Project would need to be constructed prior to the East Link Project so that HOV traffic can be moved from the center roadway to the outer roadways. Once the I‐90 Two‐Way Transit and HOV Operations Project is completed, the Center Roadway will no longer be needed for vehicular traffic and can be converted to High Capacity Transit use through the construction of the East Link Project. Alternative A1 was selected by FTA because it was the only one that met FTA’s purpose and need in this section. The Interchange Justification Report documents FHWA’s conclusion that this alternative will not adversely impact the Interstate.

112th Avenue SE Modified Alternative (B2M)

The FEIS documents the analysis of six alternatives in Segment B. The selected alternative (112th Avenue SE Modified Alternative (B2M)) is elevated in the I‐90 center roadway, crosses over westbound I‐90, and East Link Project FHWA Record of Decision November2011

continues elevated on the east side of Bellevue Way SE to the South Bellevue Station, located at the current South Bellevue Park‐and‐Ride. This alternative maintains the westbound and eastbound I‐90 HOV direct access ramps. The route proceeds along the east side of Bellevue Way with an elevated station at the existing South Bellevue Park‐and‐Ride. The South Bellevue Station includes construction of a parking garage with approximately 1400 stalls as well as bus‐transfer facilities. This alternative descends from the elevated profile and continues north along Bellevue Way and 112th Avenue NE toward downtown Bellevue. Alternative B1 would have eliminated the westbound and eastbound HOV access ramps to I‐90. Alternative B2A, B2E, and B3 would have eliminated or changed the eastbound I‐ 90 HOV ramp. Alternative B7 is elevated in the I‐90 corridor similar to B2A, B2E, and B3 and would have crossed over I‐90 and continued on the north side of I‐90 until it reached the BNSF right of way and continued north adjacent to the I‐405 corridor. The preferred alternative has the least impact on the Interstates in this segment. The Interchange Justification Report documents FHWA’s conclusion that this alternative will not adversely impact the Interstate.

110th NE Tunnel Alternative (C9T)

The selected Alternative C9T travels from Segment B in a tunnel north along 110th Avenue NE to the underground Bellevue Transit Center Station at NE 4th Street. The tunnel continues north to NE 6th Street, where it turns east and transitions to an elevated profile in the center of NE 6th Street. The route transitions to the north side of NE 6th Street to cross 112th Avenue NE, I‐405, and 116th Avenue NE. Alternative C9T then turns north along the former BNSF Railway corridor to cross NE 8th Street and reach the elevated Hospital Station.

Ten alternatives were considered in this segment. C3T, C4A, C7E, and C8E cross I‐405 north of NE 12th street. C14E crosses I‐405 between NE 6th and NE 8th. C11A, C9A, C9T (Selected Alternative) , C1T and C2T all cross I‐405 at NE 6th Street. None of these crossings, including the selected alternative, would adversely affect the operation of I‐405. The Interchange Justification Report documents FHWA’s conclusion that this alternative will not adversely impact the Interstate.

Basis for FHWA Decisions

The East Link Project Final EIS provides the transportation analysis to support FHWA decisions and approvals for the project. FHWA approvals that will be required for East Link include:

 Interchange Justification Report, which contains the analysis necessary for FHWA’s approval of the safety and operational impacts of a change in access to the Interstate System.  Airspace Lease for Use of Interstate Right‐of‐Way  Breaks‐in‐access, including those determined necessary during the design process as well as those requested during Construction East Link Project FHWA Record of Decision November2011

 Operations and Maintenance Agreement  Approval of conversion of highway lanes to high capacity transit  Approval of bridge expansion joint design

Chapter 3 and Appendix H1 (Transportation Technical Report) of the Final EIS contain analyses and results related to regional travel, transit service, highway operations and safety, arterials and local streets, non‐motorized facilities, and freight mobility and access. The Final EIS also includes analysis of the project’s consistency with regional land use and transportation plans. In addition, FHWA, FTA, Washington Department of Transportation (WSDOT), and Sound Transit worked cooperatively over a four‐year period to complete the Final Interchange Justification Report (IJR) in May 2011. On June 22, 2011, FHWA provided WSDOT a finding of engineering and operational acceptability, noting that the final IJR approval may be given at the completion of the NEPA process.

FHWA, as a cooperating agency under NEPA, and as the federal agency responsible for the anticipated project approvals noted above, has considered the findings in the Final EIS related to elements of the East Link Project affecting Interstate right‐of‐way. These findings are summarized below, as they relate to I‐90 and I‐ 405. The summary of findings is organized as they relate to highway operations, safety, construction period effects, and other environmental benefits or impacts.

Interstate 90

The East Link Project would convert the I‐90 center roadway lanes for exclusive light rail use; modify access to the I‐90 center roadway; and modify existing ramps for light rail access to and from I‐90. These modifications are fully described in the Final EIS and the Final I‐90 Interchange Justification Report.

Operations

 When compared to the No Build Alternative, the light rail project has the capacity to carry from 9,000 to 12,000 people per hour in each direction, which would more than double the person‐ carrying capacity of I‐90. The ability to carry this many people is equivalent to about seven to ten freeway lanes of vehicle traffic.

 The project would increase total person throughput across I‐90 during peak traffic periods by approximately 15 to 30 percent in 2030. In general, traffic congestion on I‐90 would be shorter in duration and extent as people shift to use light rail.

East Link Project FHWA Record of Decision November2011

 With mitigation, the project would maintain or improve peak hour traffic level‐of‐service at WSDOT controlled intersections near I‐90 on Mercer Island. In Seattle, WSDOT controlled intersections would maintain their peak hour level‐of‐service with Alternative A1.

 The project is designed to preserve both the westbound and eastbound HOV direct access ramps at the I‐90 / Bellevue Way interchange and would not result in level‐of‐service impacts at intersections.

 Freight truck access to and from I‐90 outer roadways would be unchanged because none of the general purpose ramps to and from I‐90 would be modified with the project.

 Regarding freight mobility, the average truck travel time in the afternoon peak period in 2030 would improve with an approximately 5‐minute travel time savings. Average truck travel time in the morning peak period would be comparable with the no‐build condition, with a potential 1‐ minute travel time savings.

Construction

 Before light rail is constructed on I‐90, the I‐90 Two‐Way Transit and HOV Project would be completed. The I‐90 Two‐Way Transit and HOV Project will provide outer‐roadway HOV lanes from Bellevue to Rainier Avenue to improve transit function on the I‐90 bridge and allow for future use of the reversible center roadway. The reversible center roadway and D2 Roadway would be closed during construction. As a result, all bus routes, HOVs, and Mercer Island drivers would be rerouted to the outer roadway HOV lanes. Construction impacts would be minimal because most construction would occur within the reversible center roadway. Compared to the no‐build condition, travel times for traffic and freight during peak periods would be similar or improved, although person throughput would be less in the peak directions and greater in the reverse peak directions.

 At the I‐90 and Bellevue Way interchange, the westbound mainline, HOV direct‐access ramps, and ramps to and from I‐90 to the east would experience short‐term partial (likely nighttime) closures for construction of the elevated structures. Vehicles would be detoured to the corresponding general‐purpose or HOV ramp or to another interchange.

Environmental Benefits or Impacts

As discussed above, this ROD is focused solely on FHWA’s decisions. Therefore, the environmental benefits and impacts discussed below are limited to those directly related to the portions of the project influenced by the FHWA decisions. Other benefits and impacts are presented in the FTA ROD.

East Link Project FHWA Record of Decision November2011

 The project would benefit the region by decreasing daily vehicle miles traveled (VMT) by approximately 230,000 miles and daily vehicle hours traveled (VHT) by approximately 10,000 hours, which would result in lower energy use and reduced greenhouse gas emissions

(expressed as CO2 equivalent (CO2e)). The analysis of East Link alternatives shows that there

would be a range of 21,535 to 28,835 metric tons annual reduction of CO2e emissions in the region in 2030 due to the reduction of VMT and the use of cleaner energy sources for operating the light rail system. This reduction or savings is equivalent to supplying electricity for approximately 3,175 homes for 1 year according to the EPA.

 The portion of the project along I‐90 east of the Mount Baker Tunnel (more than 5 miles) would be converted from HOV vehicle use to exclusive use by light rail, resulting in a substantial decrease (about 35 acres) of pollution generating impervious surface (PGIS).

 A segment of I‐90 in the project corridor between mileposts 3.4 and 8.9 including the Mount Baker Ridge Tunnel portals is eligible for listing on the National Register of Historic Places (NRHP). Through the Section 106 consultation process, on June 15, 2011 the Washington Department of Archaeology and Historic Preservation concurred with the Federal Transit Administration that the project is consistent with the character and design intent of I‐90 and would not impact this segment of the interstate’s NRHP eligibility.

As relates to FHWA’s decision, the chief environmental impacts are the reduction of greenhouse gasses and reduction of PGIS. These reductions render the build alternatives more environmentally preferable than the no‐build alternative. For the purposes of FHWA’s limited approvals, there is little distinction between the build alternatives as to environmental impacts. All build alternatives would reduce greenhouse gasses and PGIS roughly equally. Additionally all alternatives, including the No‐Build, would preserve the character of the historic neighborhood.

Interstate 405

The project will cross I‐405 in Bellevue with an elevated guideway at NE 6th Street. The East Link Project will not otherwise occupy I‐405 and it will not modify access to I‐405.

Operations and Safety

The elevated light rail guideway will span the mainline travel lanes of I‐405 and the NE 6th Street direct‐ access ramps. The project will not affect I‐405 operations. This crossing has been designed in coordination with Washington State Department of Transportation and will not restrict or preclude future improvements in the I‐405 Corridor Program. The project would maintain peak hour traffic level‐ of‐service at WSDOT controlled intersections near I‐405. East Link Project FHWA Record of Decision November2011

Construction

The project will require lane closures on I‐405, likely at night or on weekends depending on the construction method of the elevated structure over I‐405. Closures will likely occur adjacent to the NE 6th Street direct‐access ramps and NE 8th Street ramps to and from the south of NE 8th Street, requiring detours.

Section 4(f)

FTA has completed a Section 4(f) Evaluation for this project. All of the FHWA approvals for this project relate to the portions of the project occurring within the Interstate ROW, so there are no 4(f) uses related to the FHWA approvals.

Measures to Minimize Harm

The Federal Transit Administration Regional Administrator, the Washington State Department of Transportation, and Sound Transit ultimately will be responsible for monitoring and enforcing mitigation measures. As stated in FTA’s ROD, the mitigation measures will be incorporated into any future grant agreement that FTA may award Sound Transit for the construction of the East Link Project. The FTA’s Record of Decision contains a complete summary of required mitigation measures for the East Link Project. Mitigation measures either affecting FHWA right‐of‐way or that would be implemented within FHWA right‐of‐way are summarized below. All practicable means to avoid and minimize environmental harm have been adopted.

Highway Operations and Safety Mitigation Measures

During East Link construction, Sound Transit will coordinate with the Washington State Department of Transportation (WSDOT) on incident management, construction staging, and traffic control where the light rail construction might affect freeway traffic. Sound Transit will also coordinate with WSDOT to disseminate construction closure information to the public as needed.

Intersection Level of Service

Intersections on Mercer Island would potentially require turn pockets or traffic signal improvements to adjust for the change in travel patterns to and from the island. Improvements at intersections within WSDOT’s jurisdiction include:

 77th Avenue SE and I‐90 eastbound off‐ramp: Install a traffic signal.

East Link Project FHWA Record of Decision November2011

 76th Avenue SE/North Mercer Way and I‐90 Westbound on‐ramp: Modify the westbound channelization to provide left‐turn pocket and through/right shared lane.

These improvements would improve the AM and PM peak hour intersection LOS to the same or better than no‐build conditions. Sound Transit will be responsible for implementing improvements at the two intersections within WSDOT’s jurisdiction prior to East Link opening service.

Traffic During Construction

All mitigation measures associated with the construction of the East Link Project would comply with local regulations governing construction traffic control and construction truck routing. Sound Transit would finalize detailed construction mitigation plans in coordination with local jurisdictions and WSDOT during the final design and permitting phase of the project. Options for mitigation measures are listed below and will be implemented, as necessary, to mitigate traffic impacts due to light rail construction:

 Follow standard construction safety measures, such as installing advance warning signs, installing highly visible construction barriers, and using flaggers.

 Use lighted or reflective signage to direct drivers to truck haul routes and enhance visibility during nighttime work hours.

 Use temporary reflective truck prohibition signs on streets with a high likelihood of cut‐through truck traffic.

 In areas with high levels of traffic congestion, schedule traffic lane closures and high volumes of construction traffic during off‐peak hours to minimize delays where practical.  Provide public information through tools such as print, radio, posted signs, websites, and e‐mail to provide information regarding street closures, hours of construction, business access, and parking impacts.

 Where necessary, the contractor could be responsible for providing parking areas for construction workers.

Freight Mobility and Access Mitigation Measures

During construction associated with I‐90, SR 520, or I‐405, Sound Transit will coordinate with freight stakeholder groups by providing construction information to WSDOT for use in the state’s freight notification system. Sound Transit will provide information in a format required by WSDOT and compensate WSDOT for any direct costs associated with use of the freight notification system for East Link construction.

East Link Project FHWA Record of Decision November2011

Navigable Waterways Mitigation Measures

A Tribal fishery event on Lake Washington occurs in July. If any barging of construction equipment or materials is required, then Sound Transit will consult with the Muckleshoot Tribe to avoid conflict with the tribal fishing event.

Air Quality and Greenhouse Gases

For construction activities, Puget Sound Clean Air Agency (PSCAA) regulates particulate emissions (in the form of fugitive dust). To comply with the PSCAA policy of preventing air quality degradation, mitigation options are listed below and will be implemented as necessary and in accordance with standard practice to control particulate matter 10 microns or 2.5 microns or less in size (PM10 and PM2.5, respectively) and emissions of carbon monoxide (CO) and oxides of nitrogen (NOx) during construction of the project. Several of these measures would also reduce GHG emissions.

 Spray exposed soil with dust control agent as necessary to reduce emissions of PM10 and deposition of particulate matter.  Cover all transported loads of soils and wet materials before transport, or provide adequate

freeboard (i.e., space from the top of the material to the top of the truck) to reduce PM10 and deposition of particulate during transportation.  Provide wheel washes to reduce dust and mud that would be carried off site by vehicles and to decrease particulate matter on area roadways.  Remove the dust and mud that are deposited on paved, public roads to decrease particulate matter.  Route and schedule high volumes of construction traffic to reduce congestion during peak travel

periods and reduce emissions of CO, NOx, and carbon dioxide equivalent (CO2e) where practical.  Require appropriate emission‐control devices on all construction equipment powered by gasoline or

diesel fuel to reduce CO and NOX emissions in vehicular exhaust.

 Use well‐maintained heavy equipment to reduce CO and NOX emissions, which may also reduce GHG emissions.  Cover, install mulch, or plant vegetation as soon as practical after grading to reduce windblown particulate in the area.

The following other readily available mitigation measures could potentially be used:

 Encourage contractors to employ emissions reduction technologies and practices for both on‐road and off‐road equipment/vehicles (e.g., retrofit equipment with diesel control technology and/or use of ultra‐low sulfur diesel).  Implement construction truck‐idling restriction (e.g., no longer than 5 minutes).

East Link Project FHWA Record of Decision November2011

 Locate construction equipment and truck staging zones away from sensitive receptors as practical and in consideration of other factors such as noise.

Noise and Vibration

During final design, all predicted impacts and mitigation measures will be reviewed for verification. During final design, if it is discovered that mitigation can be achieved by a less costly means or if the detailed analysis show no impact, then the mitigation measure may be eliminated or modified.

The potential mitigation options available for noise from transit operations on the East Link Project are primarily sound walls, special trackwork, lubricated curves, and residential building sound insulation. Sound walls are proposed where feasible and reasonable, as determined by Sound Transit based on specific site conditions. Sound walls would be located on the ground for at‐grade profiles and on the guideway structure for elevated profiles. Sound walls are preferred because they are effective at reducing noise. For locations where there is a potential for traffic noise to be reflected off the sound walls, Sound Transit will propose to use absorptive treatments to remedy this issue.

A crossover track uses a frog (a rail‐crossing structure) to allow the train to either cross over to another track or continue moving on the same track. A gap is provided on top of the frog so that vehicle wheels can pass regardless of which track is in use. With typical frogs, noise and vibration are generated when the wheels pass over the gap. Special trackwork, such as movable point or spring rail frogs, eliminates the gap between tracks at crossovers that causes noise and vibration at these locations.

Sound Transit is currently investigating the use of non‐audible warnings for gated and ungated at‐grade crossings. If non‐audible warning devices are found to be viable, this option could be used to reduce or eliminate bell noise at specific crossings. Where practical, grade separation of at‐grade light rail crossings would also be considered to eliminate the need for bells or other audible warning devices. If bells are used at gated crossings, the bells would be set at the minimum noise level that maintains a safe crossing. Finally, the use of acoustic bell shrouds would be examined during final design; the shrouds would direct the bell noise at gated crossings to the intersection.

When source mitigation measures or sound walls are infeasible or not entirely effective at reducing noise levels below the FTA impact criteria, then residential sound insulation would be evaluated and implemented at impacted properties where the existing building does not already achieve a sufficient (as modeled) exterior‐to‐interior reduction of noise levels. Many newer buildings, particularly in Downtown Bellevue, have good interior noise reduction and additional sound insulation may not be necessary.

East Link Project FHWA Record of Decision November2011

I‐90

 The only potential noise impact in Seattle would be near the transition from the Mount Baker Tunnel to the floating bridge structures. A light rail expansion joint would be required to allow for bridge movement; as a result, increased noise related to this joint could occur. If, after testing of the expansion joint prototype, the expansion joint near the Mount Baker Tunnel were determined to cause a noise impact, then mitigation is likely to be a short, absorbent sound wall along the structure’s side or absorbent material applied to the existing traffic safety barriers.  No noise impacts would occur on Mercer Island. In Bellevue, noise impacts at residential properties north of I‐90 along SE 34th Street and 113th Avenue SE will be mitigated with a sound wall installed on the elevated light rail guideway.  Vibration mitigation will be required along the Mount Baker Tunnel area to mitigate groundborne noise impacts at single‐family homes along the top of the hillside.  To reduce noise levels on the Rainier Station and Mercer Island Station platforms, Sound Transit will incorporate design measures to reduce freeway noise for patrons waiting at station platforms.  For curves of 600‐foot radius or less, a trackside or vehicle‐mounted lubrication system will be used to mitigate wheel squeal noise. For curves of 600‐ to 1,000‐foot radius, the project will be designed to accommodate a lubrication system if wheel squeal occurs during operation.

I‐405

 No noise or vibration mitigation is proposed within the I‐405 right‐of‐way. Sound walls and special trackwork for the crossover will be used to mitigate noise and vibration impacts on the Coast Bellevue Hotel, located adjacent to the I‐405/NE 8th Street interchange.

Construction Period Mitigation

Several different jurisdictions are responsible for the regulation of construction noise. Most daytime construction activities will be exempt from the noise control ordinances. When required, Sound Transit or its contractor will seek the appropriate noise variance from the local jurisdiction. Sound Transit will control nighttime construction noise levels by applying noise level limits, established through the variance process, and use noise control measures where necessary. The contractor will have the flexibility of either prohibiting certain noise‐generating activities during nighttime hours or providing additional noise control measures to meet these noise limits. East Link Project FHWA Record of Decision November2011

Noise control mitigation for nighttime or daytime work will include the following measures, as necessary, to meet required noise limits:

 Install construction site noise barrier wall by noise‐sensitive receivers.  During nighttime work, use smart back‐up alarms that automatically adjusts or lowers the alarm level or tone based on the background noise level, or switch off back‐up alarms and replace with spotters.  Use low‐noise emission equipment.  Implement noise‐deadening measures for truck loading and operations.  Conduct monitoring and maintenance of equipment to meet noise limits.  Use lined or covered storage bins, conveyors, and chutes with sound‐deadening material.  Use acoustic enclosures, shields, or shrouds for equipment and facilities.  Install high‐grade engine exhaust silencers and engine‐casing sound insulation.  Prohibit aboveground jack‐hammering and impact pile driving during nighttime hours.  Minimize the use of generators or use whisper quiet generators to power equipment.  Limit use of public address systems.  Use movable noise barriers at the source of the construction activity.  Limit or avoid certain noisy activities during nighttime hours.

Pile driving might be required for construction of the elevated profile over I‐405. To mitigate noise related to pile driving, the use of an augur to install the piles instead of a pile driver would greatly reduce the noise levels. If pile driving is necessary, the only mitigation would be to limit the time of day the activity can occur. Pile driving is not expected at most construction locations.

Measures to minimize short‐term annoyance from groundborne vibration and groundborne noise from construction activities such as pile installation include use of alternate methods that result in less vibration or noise, such as auger cast piles or drilled shafts in place of driven piles. The hours and duration of these types of activities can also be restricted to hours when vibrations and noise are less noticeable.

Ecosystem Resources

BMPs will be implemented to avoid construction impacts on aquatic resources, including potential construction activity in Lake Washington (welding or bolting metal jackets together).

Sound Transit will consult with the Tribes to avoid impacting Tribal fisheries from construction work in Lake Washington, from barge/boat transit through the Lake Washington ship canal, or through approaches to the Ballard Locks. East Link Project FHWA Record of Decision November2011

Geology and Soils

Engineering design standards and BMPs will be used to avoid and minimize potential construction impacts. Based on the review of potential impacts, the design and construction process will address seismic hazards, soft soils, settlement, steep‐slope hazards, landslide hazards, erosion and sediment control, vibrations, and groundwater.

Electromagnetic Fields

The I‐90 section of the project will incorporate measures to prevent stray electrical current from corroding the steel components of the I‐90 bridge, as agreed to with WSDOT.

Public Services

Sound Transit will coordinate with public service providers before and during construction to maintain reliable emergency access and alternative plans or routes to minimize delays in response times.

Utilities

The project includes design measures and coordination with utility providers and the public to minimize impacts on utilities during light rail construction. These measures will include potholing and preconstruction surveys to identify utility locations. Sound Transit will continue to work with utility providers to minimize any potential service interruptions and perform outreach to notify the community of potential service interruptions.

Parkland and Open Space

Benvenuto Viewpoint in the City of Seattle and the Mercer Island Park on the Lid are part of the larger network of I‐90 parks along lids and overpasses. Station entrances located within these parks will be designed to be compatible with the park.

Sound Transit will restore disturbed park and open space to pre‐project conditions after construction in cooperation with the resource owner. This would include landscaping, paths, and any built features of the park. During construction, pedestrian access to parks and trails will be routed to the remaining open portions of the facilities.

East Link Project FHWA Record of Decision November2011

Determinations and Findings

The Final EIS includes a record of the comments submitted on the Draft EIS and Supplemental Draft EIS. Responses to comments were completed, along with additional environmental analysis developed as part of the Final EIS. The Final EIS also included consideration of, and findings related to, consistency with federal statues and executive orders.

FTA, as the federal lead agency, found that the Project has met all applicable standards and that all NEPA requirements have been met, as documented in its Record of Decision. FTA’s Record of Decision includes discussion of determinations and findings related to:

 National Environmental Policy Act, Environmental Quality Improvement Act and Executive Order 11514, Protection and Enhancement of Environmental Quality  Executive Order 12372 Intergovernmental Review of Federal Programs  Executive Order 13175 Consultation and Coordination with Indian Tribe Governments  Endangered Species Act (ESA) Consultation with Resource Agencies  Magnuson‐Stevens Act Finding  Migratory Bird Treaty Act, Executive Order 13186 on Migratory Birds, and the Bald and Golden Eagle Protection Act  Coastal Zone Management Act  Clean Air Act  Executive Order on Floodplain Management  Wetlands: Clean Water Act (Section 404), Executive Order 11990 on the Protection of Wetlands  Water Quality: Clean Water Act (Sections 401 and 402)  Noise Control Act of 1972, Quiet Communities Act  National Historic Preservation Act (Section 106), Executive Order 11593 on Protection and Enhancement of the Cultural Environment, and Executive Order 13007 on Protection and Accommodation of Access to Indian Sacred Sites  Department of Transportation, Section 4(f)  Land and Water Conservation Fund Act of 1965, Section 6(f)  Environmental Justice

Comments on the East Link Final EIS and Responses

Following publication of the East Link Final EIS, FTA, FHWA, and Sound Transit received comment letters related to the FEIS or the Section 4(f) and Section 106 processes. Comment letters were received from

East Link Project FHWA Record of Decision November2011

members of the public, interest groups and organizations, businesses, local jurisdictions, and other federal agencies. The primary highway‐related concerns raised and the responses to them are:

 Questions related to why alternative transit modes (e.g., enhanced bus, bus rapid transit, transportation system management (TSM)) were not analyzed as build alternatives to light rail technology on I‐90.

The purpose of the East Link project is to expand Sound Transit’s Link Light Rail system from Seattle to Mercer Island, Bellevue, and Redmond via I‐90 and to provide a reliable and efficient alternative for moving people throughout the region. Alternatives to light rail technology, including TSM and enhanced bus/BRT, were evaluated and eliminated from further review during the Sound Transit Long‐Range Planning and ST2 development process. FTA considered the mode analysis planning history and comments received during the scoping process beforee finalizing th East Link Purpose and Need. FTA, as lead federal agency, determined that planning level decisions regarding mode (LRT) and corridor (I‐90) would be incorporated into the purpose and need, consistent with federal rules and guidance for linking the transportation planning and NEPA processes (see 23 CFR Sections 450.212 and 450.318 and Appendix A to Part 450 – Linking the Transportation Planning and NEPA Processes, Final Rule (Federal Register: February 14, 2007, Vol. 72, Number 30) and guidance found at: http://environment.fhwa.dot.gov/integ/related.asp

 Questions related to the relationship between East Link and the I‐90 Two‐Way Transit and HOV Operations Project and Washington State constitutional issues related to converting highway travel lanes to transit only.

The I‐90 Two‐Way Transit and HOV project is independent of the East Link project and had a separate NEPA process, and in approving the I‐90 Two‐Way Transit and HOV Operations Project Record of Decision, FHWA determined that the project would not have adverse effects on operation of the national interstate system. As part of the identification of the preferred alternative for the I‐90 Two‐Way Transit and HOV Operations Project, the lead agencies identified the selected alternative as the first step towards the ultimate configuration of I‐90 with high capacity transit deployed in the center roadway. The existing center roadway HOV lanes will not be converted to light rail until the I‐90 Two‐Way Transit project adding additional HOV lanes has been completed. There will be no net loss of HOV lanes.

As discussed in the Executive Summary of the East Link Final EIS (ES.10, Areas of Controversy and Issues to be Resolved), in 2009 a lawsuit was filed by Eastside Transportation Association and others challenging the State of Washington’s constitutional authority to approve use of the I‐90 floating bridge center roadway for light rail transit. Petitioners sought a writ of mandamus barring the governor or secretary of transportation from “taking any action” pertaining to the conversion of lanes of I–90 for purposes of light rail. In April 2011, the Washington State Supreme East Link Project FHWA Record of Decision November2011

Court denied petitioners’ request. Following the Supreme Court’s decision, the petitioner filed a similar challenge in Kittitas County Superior Court. The Kittitas lawsuit is pending.

 Concern related to the technical feasibility of installing and operating light rail transit on the center roadway of the I‐90 floating bridges.

As described in Chapter 2 of the FEIS, the Washington State Legislature Joint Transportation Committee commissioned an independent review team (IRT) to evaluate several design issues related to installing and operating light rail on the I‐90 floating bridge, such as expansion joints, weight, stray currents, and bridge maintenance. At the time of the IRT’s final report in 2008, the team concluded that all issues identified as potentially affecting feasibility can be addressed through project design measures, provided that the resolutions and recommendations included in that report are addressed. An IRT task force continues to advance work on design solutions to all the issues identified by the IRT and specific design measures will continue to be refined throughout the final design phase of the project. For example, Sound Transit will continue work on a track bridge prototype design and testing program, which will include construction and testing of a full scale track bridge prototype prior to installation on I‐90 at the existing expansion joints. FHWA will need to approve the final design for the changes to the I‐90 bridge. The technical issues associated with the I‐90 floating bridge are discussed on pages 2‐22 and 2‐23 of the Final EIS.

 Concern related to the transportation analysis for the project on I‐90, specifically on traffic congestion, impacts to freight truck traffic, projected ridership and mode share.

There were many different comments on various aspects of the transportation analysis. Please see attachment C for responses to each of the specific comments. The FEIS analysis of transportation is included in section 3.1 of the FEIS. This section describes the transportation analysis in detail. FHWA’s review and analysis of transportation impacts has been focused on the impacts to the Interstate system (in this case to I‐90 and I‐405). FHWA’s analysis of the I‐405 crossing was limited to ensuring that FHWA’s requirements for an airspace lease are met – this focuses on the crossing providing sufficient clearances and being structurally sound. The crossing of I‐405 does not impact vehicular access to the Interstate. Changes in access to the Interstate, such as the addition of the Light Rail on I‐90, require an Interchange Justification Report (IJR) which must be reviewed and approved by FHWA. FHWA’s IJR addressed the design, safety, and operational considerations of the selected alternative. FHWA determined that the IJR contained sufficient analysis to show that East Link will not have an adverse operational or safety impact on I‐90.

FHWA’s review of the IJR resulted in confirmation that the report adequately addresses the requirements of the Policy on Added Access to the Interstate. FHWA issued a finding

East Link Project FHWA Record of Decision November2011

of engineering and operational acceptability on June 22, 2011. The IJR can be approved upon completion of the NEPA process.

None of the comments received on the FEIS related to FHWA’s approval actions for the I‐405 crossing in Bellevue. Responses to the comment letters which were primarily concerning FHWA approvals are included in Attachment C of this Record of Decision. Responses to all comments received are included in FTA’s Record of Decision.

East Link Project FHWA Record of Decision November2011

Attachment A: Map of the Selected Alternative

East Link Project FHWA Record of Decision November2011

East Link Record of Decision – Attachment A: Selected Alternative

Attachment B: Maps of the Alternatives Analyzed in the Final EIS

East Link Project FHWA Record of Decision November2011

341526.H2.02.10_TB092007009SEA_East_LInk_DEIS_Maps/05-08/Seg_A_All_v4_08-20-08 . gr 92ND 92ND AVENE To University AVENE 100TH of Washington NE 12TH ST

NE 8TH ST E MADISON ST NE 6TH ST B E L L E V U E

BOREN AVE

SEATTLE TUNNEL S E A T T L E MAIN ST E CHERRY ST Lake Washington BELLEVUE

International E YESLER WAY District/ WAY SE Chinatown S JACKSON ST Station Mt. Baker I-90 Parks 23RD AVE 23RD Tunnel on the LID Segment A JUDKINS PARK AND LAKE I-90 Floating PLAYFIELD WASHINGTON Bridge A1 LUTHER BLVD Mercer BURBANK Island 2-7 MERCER PARK SAM SMITH Station

AIRPORT WAY S AIRPORT Rainier ISLAND PARK 72ND AVESE LID Station PARK AVESE 76TH Mercer Island

Park & Ride

77TH AVESE 77TH

1ST S AVE 1ST 4TH 4TH AVES

RAINIER AVE S SE 80TH

Segment Segment UPPER L A LUTHER B K W MERCER WAY E A BURBANK

A PARK

S H SE 36TH ST I N G T GALLAGHER O SE 40TH ST N HILL OS

S SPOKANE ST B L

V M L KING L M D Y M E R C E R A W

BEACON AVE S R E C I S L A N D R E M

JR WAY S ISLAND CREST WY E

To Sea-Tac Airport

Preferred Alternative Other Alternatives Segment Limit At-Grade Route At-Grade Route Traction Power Substation CentralAdjacent Link Alignment Segment N and Station Tunnel Route Tunnel Route Station Central Link Alignment SCALE Exhibit B-1 AB Segment Limit and Station Segment A, Interstate 90 0 0.5 Mile East Link Project

DRAFT — For internal discussion only. Not reviewed or approved by or on behalf of any party. 1T A AV 112TH SE E

Segment C SE 6TH ST LAKE HILLS CONN EC Segment SURREY TO B BNSF R

B3 R DOWNS D

PARK Wilburton Ke Park & Ride lsey Creek

108TH AVESE 108TH SE 8th Station ST B2A SE 8TH B7 B1

BELLEVUE B2M to C11A B3 114th Design Option B3 118th BNSF

WAY SE Station 104TH AVESE 104TH B2E

B2M to C9T a

E t s h

g e AVE 118TH

u W o l MERCER h B2A S g u r B3 o e SLOUGH l c S r e r NATURE e M

BE LLEVUE e PARK S E

Segment B, South Bellevue B2A B2E BELLEVUE Preferred Alternative B3 B2M

B2M 112th SE to C9T E S E V A D R 3 2 1 SCALE Other Alternatives WAY SE B7 0 0.125 0.25 Mile B1 Bellevue Way B2A 112th SE At-Grade 112th SE Elevated B2E B1 B2M 112th SE toSE C11A 25TH ST BNSF

B3 112th SE Bypass E S E V A H T 8 0 1 MERCER B3 114th SE Design Option SLOUGH South Bellevue B7 BNSF Park & Ride NATURE South PARK Bellevue Station B E A U X A R T S B2A B2E B3

u o l S

B1 r e c L B2A r a e k B2E e M W Segment B3 E S E V A H T 3 1 1 a s Segment B7 h in g t B on A B7 B2M

B1 MERCER SLOUGH NATURE PARK

Source: City of Bellevue (2005) and King County (2006). Preferred Alternatives OtherAlternatives Traction Power Substation At-Grade Route At-Grade Route Station Elevated Route Elevated Route New and/or Expanded Exhibit B-2 Retained-Cut Route Retained-Cut Route Park-and-Ride Lot Segment B, South Bellevue Retained-Fill Route Retained-Fill Route AB Segment Limit East Link Project Segment C, Ashwood/ Segme Downtown Bellevue Hospital nt D S Station egmen Preferred Alternative t C NE 12TH ST C9T 110th NE Tunnel For McCORMICK PARK C3T C1T Other Alternatives C4A C2T For C7E C8E C9A C1T Bellevue Way Tunnel NE 12TH ST C11A C14E C2T 106th NE Tunnel ASHWOOD 108th NE Tunnel PARK C3T Lake C4A Couplet NE 10TH ST C9T Bellevue C7E 112th NE Elevated E N E V A H T 6 11 C8E 110th NE Elevated C9A 110th NE At Grade 108th NE At Grade Hospital

C11A E N E V A H T 8 0 1

E N E V A H T 2 11 E N E V A H T 0 11 114th NE Elevated Station C14E NE 8TH ST NE 8TH ST C14E C8E C7E BE LLEVUE C4A C4A C11A C9T NE 6TH ST Bellevue

Transit Center S

BNSF t

Bellevue u

r t

Transit e C1T v Center a n E N Y A W E U V E LL E B C2T

Station C C9A r NE 4TH ST e C11A e C9T k C1T C2T C3T NE 4TH ST

DOWNTOWN C4A C11A C8E C14E PARK C9A

NE 2ND ST CONNECTORS E N E V A H T 4 11

Old C9T Bellevue Station MAIN ST E N E V A H T 2 11

108th East Main Station C4A, C7E, 9A Station from B2A Station location associated with

C9T East C8E only E S E V A SCALEH T 6 11

E S E V A H T 8 0 1 E S E V A H T 6 0 1 Main Station Design Option 0 0.125 Mile C2T, C3T, E S Y A W E U V E LL E B C3T from B2A C4A, C7E, C9A from B2E C9T from B2M C2T, C3T, C4A, C7E, C8E, C9A, C1T C11A from B2M C2T, C3T, C9T, C11A, C14E from C4A, C7E, from B3 114th B1 C8E, C9A, Design Option C2T from B2A ,C11A , or B7 C9T BNSF C14E from B3 Segment C SE 6TH ST Segment B

SURREY DOWNS PARK

Source: City of Bellevue (2005) and King County (2006). Preferred Alternative Other Alternatives Traction Power Substation At-Grade Route At-Grade Station Elevated Route Elevated New and/or Expanded Exhibit B-3 Retained-Cut Route Retained-Cut Park-and-Ride Lot Retained-Fill Route Retained-Fill Segment C, Downtown Bellevue Tunnel Tunnel BC Segment Limit East Link Project

Attachment C: Comments Received on the Final EIS and Responses

[Letters sent directly to FHWA and/or Otherwise address I‐90]

 Bill Hirt  Eastside Transportation Association (Eager/Paylor)  Kemper Development Co.(Nurse)  Washington Trucking Association (Pursely)  Will Knedlik  James MacIsaac  William Popp  CETA (Niles/Fimia)  Alfred Cecil

East Link Project FHWA Record of Decision November2011

Letter ELFEIS005 Bill Hirt Response to comment ELFEIS005‐1 Page 1 Your comment has been noted. Please see responses to your comments below.

Response to comment ELFEIS005‐2 Please refer to Section 2.6 of the FEIS for a description of project costs and funding, including a description of Sound Transit’s policy for funding capital projects across the five subareas within its taxing district. This section also describes the projected revenue shortfall over the life of the voter approved ST2 program resulting from the recent economic recession. These constraints reiterate the need to maintain project costs within or under budget.

Response to comment ELFEIS005‐3 The transportation analysis along I‐90 is provided in Section 3.5 of the Final EIS. This analysis concludes that the project will increase overall person throughput on I‐90 in both AM and PM peak periods and have similar or improved travel times for vehicles. By year 2030, it is assumed that East Link trains would operate every 7 minutes during peak periods. Refer to the East Link operating plan located in Appendix E for the light rail operating plan. Additionally, Section 3.5.3.3 provides information on the East Link project capacity, which is a different measure than the operating plan. Capacity is equivalent to seven to ten freeway lanes, based on average persons per vehicle data on I‐90 provided by WSDOT. More than one park and ride is planned along the preferred alternative alignment. Park and Rides currently exist or are planned as part of this project at Mercer Island Station, South Bellevue Station, 130th Station, Overlake Village Station, Overlake Transit Center Station, and SE Redmond Station.

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Response to comment ELFEIS005‐4 Your comment regarding permits has been noted. Please see Section 3.5 of the Final EIS for a description of highway operations and safety. The ST2 funding package, approved by voters in 2008, provides funding for light rail between downtown Seattle and Overlake. These funds cannot simply be transferred to other projects.

Response to comment ELFEIS005‐5 The purpose of the East Link project is to expand Sound Transit’s Link Light Rail system from Seattle to Mercer Island, Bellevue, and Redmond via I‐90 and to provide a reliable and efficient alternative for moving people throughout the region. Alternatives to light rail technology, including TSM and enhanced bus/BRT, were evaluated and eliminated from further review during the Sound Transit Long‐Range Planning and ST2 development process. The history of this planning process is documented in the report titled “East Corridor High Capacity Transit Mode Analysis History” (August 2006) and discussed in Section 1.3 of the Final EIS [Purpose and Need]). For example, as described on page 21 of the Mode Analysis History report, the 1993 the Regional Transit System Plan Final EIS evaluated eastside alternatives that included converting the I‐90 center roadway to a two‐way busway (the TSM alternative). During the scoping process for the East Link EIS in 2006, the Mode Analysis History report was available for review and public comment was invited on the draft Purpose and Need Statement for the East Link EIS. FTA considered the mode analysis planning history and comments received during the scoping process before finalizing the East Link Purpose and Need. FTA, as lead federal agency, determined that planning level decisions regarding mode (LRT) and corridor (I‐90) would be incorporated into the purpose and need, consistent with federal rules and guidance for linking the transportation planning and NEPA processes (see 23 CFR Sections 450.212 and 450.318 and Appendix A to Part 450 – Linking the Transportation Planning and NEPA Processes, Final Rule (Federal Register: February 14, 2007, Vol. 72, Number 30) and guidance found at: Response to comment ELFEIS005‐7 http://environment.fhwa.dot.gov/integ/related.asp The merge near International District / Chinatown Station will be able to safely accommodate the two operating lines. The I‐90 Two Way Transit and HOV Operations Environmental Impact Statement analyzed several options for allowing transit and HOV operations to occur in both Response to comment ELFEIS005‐8 directions across I‐90, including converting the center roadway to transit and HOV Section 3.5.3.3 of the Final EIS includes the I‐90 transportation analysis only lanes (Alternative R‐2B) and adding transit only shoulder lanes that would and vehicle travel time. Section 3.4.3.3 and Table 3‐8 include the travel operate in the opposite direction of the reversible center roadway (Alternative R‐ time savings for transit riders. 5). Further information is available here: http://www.wsdot.wa.gov/projects/i90/twowaytransit/.

Response to comment ELFEIS005‐6 The capacity of East Link, which is between 18,000 and 24,000 people per hour, is based on a maximum LRT headway of 4 minutes and a person capacity per train car of 600 to 800 riders. This is different than the expected ridership in 2030. The assumption that East Link trains can operate with headways of up to 4 minutes is beyond the current planning horizon year 2030, which assumed a 7 minute headway. Four minute headways would occur when the system is at maximum operational capacity. Table 3‐6 and Section 3.4.3 of the Final EIS provide information on passenger level of service, which would be the same or better with the East Link Project during the PM peak‐hour commute.

As described in Chapter 2 of the FEIS, the Washington State Legislature Joint Transportation Committee commissioned an independent review team (IRT) to evaluate several design issues related to installing and operating light rail on the I‐ 90 floating bridge, such as expansion joints, weight, stray currents, and bridge maintenance. At the time of the IRT’s final report in 2008, the team concluded that all issues identified as potentially affecting feasibility can be addressed through project design measures, provided that the resolutions and recommendations included in that report are addressed. An IRT task force continues to advance work on design solutions to all the issues identified by the IRT and specific design measures will continue to be refined throughout the final design phase of the project. For example, Sound Transit will continue work on a track bridge prototype design and testing program, which will include construction and testing of a full scale track bridge prototype prior to installation on I‐90 at the existing expansion joints. Page 3

Response to comment ELFEIS005‐9 The ST2 funding package, approved by voters in 2008, provides funding for light rail between downtown Seattle and Overlake. These funds cannot simply be transferred to other projects.

Response to comment ELFEIS005‐10 The transportation analysis along I‐90 is provided in Section 3.5 of the Final EIS, and Section 3.5.3.3 provides additional information on the East Link project capacity, which is equivalent to seven to ten freeway lanes. The East Link capacity calculation assumes that East Link trains can operate with headways of up to 4 minutes, which is beyond the current planning horizon (2030) and is not used as part of the ridership forecast. Four minute headways would occur when the system is at maximum operational capacity. Because East Link will not be operating at capacity with 4 minute headways within the planning horizon of 2030, page 3‐25 of the FEIS presents a ridership forecast of 50,000 riders per day based on operating with 7 minute headways for 2030.

This analysis concludes that the project would increase overall person throughput on I‐90 in both AM and PM peak periods and have similar or improved travel times for vehicles. As stated in Section 3.5.3.3; “One of the key reasons the East Link project would transport more people across I‐90 is because bidirectional light rail would be a more efficient use of the center roadway space than the current reversible, one‐directional vehicles operations. The roadway’s restricted access and egress also limit vehicle capacity and throughput.”

Response to comment ELFEIS005‐11 The technical issues associated with the I‐90 floating bridge are discussed on pages 2‐22 and 2‐23 of the Final EIS. Please also see response to comment ELFEIS005‐6 above for a discussion of the independent review

team (IRT) findings and the status of resolving design issues identified by the IRT. Page 4

Response to comment ELFEIS005‐12 Your comment has been noted. The ST2 funding package, approved by voters in 2008, provides funding for light rail between downtown Seattle and Overlake. These funds cannot simply be transferred to other projects.

Please see Section 3.5 of the Final EIS for a description of highway operations and safety which shows that the project would have either similar or improved vehicle travel times and increased person throughput across Lake Washington in both the AM and PM peak periods compared to the No Build Alternative.

Response to comment ELFEIS005‐13 Your comment has been noted.

Letter ELFEIS008 Eastside Transportation Association Response to comment ELFEIS008‐1 Page 1 The East Link Project would dedicate the I‐90 center roadway for high capacity transit as stipulated in the 1976 Memorandum Agreement (as amended in 2004) among Seattle, Mercer Island, Bellevue, King County Metro, and WSDOT. At the same time, additional roadway capacity on I‐ 90 will be provided by the I‐90 Two‐Way Transit and HOV Operations Project (also known as the R‐8A Project). The additional roadway capacity from the R‐8A Project is included in the East Link Final EIS No Build Alternative as described on pages 2‐6 through 2‐9 of the Final EIS. The R‐ 8A Project is restriping I‐90 and making other improvements to add new HOV lanes to the I‐90 bridge in each direction of travel. The FHWA Record of Decision for the I‐90 Two‐Way Transit and HOV Project (September 2004) found that the Selected Alternative (Alternative R‐8A) was chosen in part because it “would accommodate the ultimate configuration of I‐ 90 (High Capacity Transit in the center lanes). Alternative R‐8A adds directional HOV lanes on the outer roadways which would provide for reliable transit and HOV operations with the ultimate roadway configuration.”

The environmental impacts from the use of the I‐90 center roadway for the East Link Project are analyzed in the East Link Final EIS. The environmental impacts for the R‐8A Project are analyzed in the 2004 Final EIS for the I‐90 Two‐Way Transit and HOV Operations Project.

denied petitioners’ request. Following the Supreme Court’s decision, the petitioner filed a similar challenge in Kittitas County Superior Court. The Kittitas lawsuit is pending.

In FHWA’s Interchange Justification Report approval letter of the East Link project (please see Appendix G of Appendix H1 [Transportation Technical Report]), FHWA determined that the project would not have adverse effects on operation of the national interstate system. FHWA determinations related to use of Interstate ROW for the East Link project are limited in scope to the East Link project. Use of Interstate ROW for any other transit, rail or other projects on any part of the Interstate system would require separate FHWA review and approval. Additionally, for the East Link project, it should be noted that HOV lanes will not be converted to light rail until the I‐90 Two‐Way Transit project adding additional HOV lanes has been completed. There will be no net loss of HOV lanes.

Response to comment ELFEIS008‐2 The purpose of the East Link project is to expand Sound Transit’s Link Light Rail system from Seattle to Mercer Island, Bellevue, and Redmond via I‐90 and to provide a reliable and efficient alternative for moving people throughout the region. Alternatives to light rail technology, including TSM and enhanced bus/BRT, were evaluated and eliminated from further review during the Sound Transit Long‐Range Planning and ST2 development process. The history of this planning process is documented in the report titled “East Corridor High Capacity Transit Mode Analysis History” (August 2006) and discussed in Section 1.3 of the Final EIS [Purpose and Need]). For example, as described on page 21 of the Mode Analysis History report, the 1993 the Regional Transit System Plan Final EIS evaluated eastside alternatives that included converting the I‐90 center roadway to a two‐way busway (the TSM alternative). During the scoping process for the East Link EIS in 2006, the Mode Analysis History report was available for review and public comment was invited on the draft Purpose and Need Statement for the East Link EIS. FTA considered the mode analysis planning history and comments received during the scoping process before finalizing the East Link Purpose and Need. FTA, as lead federal agency, determined that planning level decisions regarding mode (LRT) and corridor (I‐90) would be incorporated into the purpose and need, consistent with federal rules and guidance for linking the transportation planning and NEPA processes (see 23 CFR Sections 450.212 and 450.318 and Appendix A to Part 450 – Linking the Transportation Planning and NEPA Processes, Final Rule (Federal Register: February 14, 2007, Vol. 72, Number 30) and guidance found at: http://environment.fhwa.dot.gov/integ/related.asp

Response to comment ELFEIS008‐3 Your comment has been noted. Please see response to comment # ELFEIS008‐1. Petitioners’ constitutional challenge and request for a writ of mandamus was denied by the Washington Supreme Court in April 2011. The Kittitas lawsuit is pending.

Response to comment ELFEIS008‐4 Appendix A of Appendix H1 of the Final EIS for the Transportation Methods and Assumptions Report provides information on how the East Link transportation analysis was prepared.

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Response to comment ELFEIS008‐5 The information presented in the figure for 2030 Build and No Build Transit Trips does not come from the Final EIS. Based on the information provided in the comment, it is unclear how the No Build and Build Transit Trips depicted in this figure were determined. Sound Transit’s ridership estimates are determined from the Sound Transit ridership patronage model, which has been reviewed by the Federal Transit Administration and two State Expert Review Panels. This model incorporates residential and employment growth forecasts developed by the Puget Sound Regional Council, predicting that transit demand in the No‐Build Alternative will double across Lake Washington by year 2030. With the East Link project, it is forecasted that transit ridership across Lake Washington would increase by about 25 percent from the No‐Build Alternative. This is summarized in Section 3.1 and described in more detail in Sections 3.4 and 3.5 of the Final EIS.

Response to comment ELFEIS008‐6 Table 3‐2 in Appendix H1 of the Final EIS provides Screenline 2 (Lake Washington) person mode share information for both SR 520 and I‐90 combined. Therefore it is not reasonable to compare that mode share data to mode share data for I‐90 only. The percentages you refer to are not consistent with the definition presented in the Final EIS for growth in transit mode share. Refer to Table 3‐19 for the person mode share information for the No‐Build and Build conditions for both I‐90 and SR 520 crossings. Exhibit 5‐6 in Appendix H1 provides mode share information on I‐90 only.

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Response to comment ELFEIS008‐7 East Link’s capacity is estimated to be 18,000 to 24,000 people per hour. This is not considered a ridership forecast, but is an estimate of how many people could ride the East Link system. The East Link capacity calculation provides a high‐level understanding of what this project could achieve but was not utilized in any of the transportation analysis documented in the East Link Final EIS. More appropriately, the ridership forecasts from Sound Transit’s model, which predicts approximately 50,000 daily riders by year 2030, was used in the environmental analysis.

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Response to comment ELFEIS008‐8 The statement cited is accurate as currently there are eight travel lanes on I‐90 across Lake Washington; six of those lanes are designated for general‐purpose use and two of those lanes are HOV designated. With East Link, there will be eight travel lanes; six of which will be designated for general‐purpose traffic and two HOV lanes. As described in Section 2.3.1 of the Final EIS, one No Build Alternative scenario analyzed assumes completion of all stages of the I‐90 Two‐Way Transit and HOV Operations Project. While the I‐90 Two‐Way Transit and HOV Operations Project received a Record of Decision in 2004, those outer roadway HOV lanes on the I‐90 bridge have not been constructed. They are expected to be operational before the center roadway is closed for East Link construction.

Response to comment ELFEIS008‐9 While the 2006 WSDOT I‐90 Center Roadway Study and the 2011 East Link Final EIS were conducted with appropriate transportation analysis methods, the two analyses use different modeling approaches. Refer to Appendix H of Appendix H1 of the East Link Final EIS for a description and overview of the recent I‐90 Transportation Studies, including the differences in modeling parameters and assumptions used in the 2006 Center Roadway Study. The East Link Project assumed a set of reasonable assumptions and methodologies that were based on decisions and agreements since the Center Roadway Study was published. Some of these differences include: the East Link analysis assuming tolling on SR 520; utilizing the latest release of the Puget Sound Regional Council's regional travel demand model at the time of analysis; incorporating Sound Transit's ridership transit forecasts into the PSRC forecasts; and assuming a different usage in the I‐90 HOV lanes. Additionally, the Center Roadway Study deferred some technical efforts that the East Link project conducted in greater detail. Therefore the East Link analysis better reflects the current understanding of future travel conditions along I‐90 when compared to the 2006 Center Roadway Study. Further, Page 6 the Center Roadway Study confirmed the utility of the center roadway as an HCT facility with no center roadway access for vehicles. WSDOT is a co‐lead for the East Link Final EIS, and the transportation analysis provided in the 2011 Final EIS was reviewed and approved by WSDOT.

Response to comment ELFEIS008‐10 The I‐90 Two‐Way Transit and HOV Operations Project ROD relates to that specific project and not the future use of the center roadway after that project’s completion. The quoted statement refers to a description of Alternative R‐8A in the ROD. The 2004 FHWA ROD also states that basis for selecting Alternative R‐8A is in part because that alternative “would accommodate the ultimate configuration of I‐90 (High Capacity Transit in the center lanes). Alternative R‐8A adds directional HOV lanes on the outer roadways which would provide for reliable transit and HOV operations with the ultimate roadway configuration.”

Response to comment ELFEIS008‐11 Please see response to comment #ELFEIS008‐9 for the comparison between the 2006 Center Roadway Study and the 2011 East Link FEIS. The elements of the I‐90 Two‐Way Transit and HOV Operations Project, including the narrower shoulder and travel lanes and weaving sections, were evaluated in the Final EIS for that project, which can be found here: http://projects.soundtransit.org/Projects‐Home/Project‐List/I‐90‐Two‐ Way‐Transit‐and‐HOV‐Operations‐Stage‐1/Final‐EIS‐for‐Interstate‐90‐ Two‐Way‐Transit‐and‐HOV‐Operations‐Project.xml. The East Link Final EIS transportation analysis incorporates these project features as part of the baseline, or “No Build” transportation network for future year conditions (see Table 2‐1 on page 2‐8 of the East Link Final EIS).

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Response to comment ELFEIS008‐12 Please refer to the response to comment ELFEIS008‐2 for discussion of the planning history in the corridor, which considered and evaluated other transit modes on I‐90; and FTA's consideration of this planning history as well as scoping comments received during the East Link scoping process prior to determining the final purpose and need for East Link.

Changes in access to the Interstate require an Interchange Justification Report (IJR) which must be reviewed and approved by FHWA. The IJR must be developed in accordance with the requirements of FHWA’s Policy on Access to the Interstate System (published in the Federal Register on August 27, 2009). Policy Point 2 states: "The need being addressed by the request cannot be adequately satisfied by reasonable transportation system management (such as ramp metering, mass transit, and HOV facilities), geometric design, and alternative improvements to the Interstate without the proposed change(s) in access (23 CFR 625.2(a))”. Per FHWA's policy, analysis needs to be provided that addresses the design, safety, and operational considerations of these alternatives. Please note, as reflected in Policy Point 2, FHWA’s policy considers mass transit, such as light rail, to constitute reasonable transportation system management. FHWA determined that the IJR for this project provided adequate documentation in Policy Point 2 about how the Light Rail option was selected over other transit alternatives during the Sound Transit Long‐Range Planning and ST2 development processes and that the IJR in Policy Point 3 contains sufficient analysis to show that East Link will not have an adverse operational or safety impact on I‐90 by increasing person capacity and throughput across Lake Washington, having similar or improved vehicle travel times and reducing the number of accidents per person on I‐90. FHWA’s review of the IJR resulted in confirmatione that th report adequately addresses the requirements of the Policy on Added Access to the Interstate. FHWA issued a finding of engineering and operational acceptability on June 22, 2011. The IJR will be approved upon completion of the NEPA process.

Response to comment ELFEIS008‐13 The figures you present for ridership and mode shift do not come from the Final EIS. Based on the information provided in the comment, it is unclear how the numbers depicted in this figure were determined. Mode share information on both the I‐90 and SR 520 crossings of Lake Washington is provided in Table 3‐19 of Chapter 3 of the Final EIS. This table provides the shift in SOV, HOV and Transit modes with and without the East Link Project across Screenline 2 (Lake Washington). The East Link project is forecasted to have approximately 50,000 daily riders by year 2030 and about 10,000 will be new transit riders.

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Response to comment ELFEIS008‐14 Please refer to Appendix F4.2 for how the East Link project is consistent with specific regional and local long‐range plans within the study area. The Sound Transit figures you present (2,500 daily transit trips) do not come from the Final EIS. The source document you cite (BKR Documentation Report) was prepared by the City of Bellevue, not Sound Transit. The daily trips estimated in that report (350,000 in 2008 and 695,000 in 2030) represent all motorized trips for all motorized modes (transit, SOV, HOV) into, out of, and within downtown Bellevue. This report does not indicate what percentage of the 695,000 person trips are estimated for East Link or other transit modes, so it is not clear how you derived the 2,500 daily transit trips you show in this graph. As indicated in Section 3.4 of the Final EIS, East Link would carry up to 50,000 daily riders and up to 8,000 of those would be from Segment C (downtown Bellevue) stations.

Response to comment ELFEIS008‐15 The figures for East Link trips in downtown Bellevue you present do not come from the Final EIS. It is unclear how the 350 East Link trips during the 2030 PM peak hour you reference were determined. As shown in Table 6‐17 of the Transportation Technical Report (Appendix H1 to the FEIS), the estimated 2030 PM peak‐period (3‐hour) station ridership at the Bellevue Transit Center is over 6,000. This estimate includes pedestrian and bicyclist access as well as bus transfers at the transit center. An un‐served demand into and out of Downtown Bellevue further highlights the need for light rail.

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Response to comment ELFEIS008‐16 Vanpools are an important transportation mode in the Puget Sound region and have a specific market they serve – usually coworkers or people who work in the same vicinity who volunteer to drive, fuel, clean and schedule maintenance and repair for the van (source WSDOT website http://www.wsdot.wa.gov/Choices/rideshare.htm). Light rail serves different markets by connecting employment and population centers with frequent reliable service. Vanpools do not meet the purpose for the East Link project, which is to expand the Sound Transit Link light rail system from Seattle to Mercer Island, Bellevue and Redmond via Interstate 90, as stated in Chapter 1 of the Final EIS. Please also refer to response to comment #ELFEIS008‐2 for more information regarding the planning history which considered various transit modes in the East Corridor. Funds for construction of the East Link Project have already been approved by voters as part of ST2 in November 2008.

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Letter ELFEIS011 Kemper Development Company Response to comment ELFEIS011‐1 Page 1 Thank you for your comments. Please see Section 2.6 of the Final EIS for a discussion of costs and funding, Section 2.7 for the project schedule and Chapter 3 for transportation changes that would result from the project. Please see responses to the subsequent comments in this letter regarding alleged flaws and omissions.

Response to comment ELFEIS011‐2 Your comment has been noted. Please see Appendix B of the Final EIS for a description of public involvement that took place before the November 2008 vote on the Sound Transit 2 Plan.

As discussed in the Executive Summary of the East Link Final EIS (ES.10, Areas of Controversy and Issues to be Resolved), in 2009 a lawsuit was filed by Eastside Transportation Association and others challenging the State of Washington’s constitutional authority to approve use of the I‐90 floating bridge center roadway for light rail transit. Petitioners sought a writ of mandamus barring the governor or secretary of transportation from “taking any action” pertaining to the conversion of lanes of I–90 for purposes of light rail. In April 2011, the Washington State Supreme Court denied petitioners’ request. Following the Supreme Court’s decision, the petitioner filed a similar challenge in Kittitas County Superior Court. The Kittitas lawsuit is pending.

The Sound Transit Board identified light rail as the preferred mode using a route along I‐90 in July of 2006. In July of 2008 the Sound Transit Board adopted Sound Transit 2: A Mass Transit Guide, the Regional Transit System Plan. The East Link Light Rail Transit Project is included in ST2. ST2 was approved by voters in November 2008. Please see Section 3.5 in the Final EIS for a discussion of impacts to I‐90 and Section 3.8 for a discussion of impacts to truck routes. Please see Section 1.2 of the Final EIS for a description of the need for the East Link Project.

Page 2 In approving of the I‐90 Two‐Way Transit and HOV Operations Project Record of Decision, FHWA determined that the project would not have adverse effects on operation of the national interstate system. FHWA determinations related to use of Interstate ROW for the East Link project are limited in scope to the East Link project. Use of Interstate ROW for any other transit, rail or other projects on any part of the Interstate system would require separate FHWA review and approval. Additionally, for the East Link project, it should be noted that HOV lanes will not be converted to light rail until the I‐90 Two‐Way Transit project adding additional HOV lanes has been completed. There will be no net loss of HOV lanes.

Response to comment ELFEIS011‐3 The purpose of the East Link project is to expand Sound Transit’s Link Light Rail system from Seattle to Mercer Island, Bellevue, and Redmond via I‐90 and to provide a reliable and efficient alternative for moving people throughout the region. Alternatives to light rail technology, including TSM and enhanced bus/BRT, were evaluated and eliminated from further review during the Sound Transit Long‐Range Planning and ST2 development process. The history of this planning process is documented in the report titled “East Corridor High Capacity Transit Mode Analysis History” (August 2006) and discussed in Section 1.3 of the Final EIS [Purpose and Need]). For example, as described on page 21 of the Mode Analysis History report, the 1993 the Regional Transit System Plan Final EIS evaluated eastside alternatives that included converting the I‐90 center roadway to a two‐way busway (the TSM alternative). During the scoping process for the East Link EIS in 2006, the Mode Analysis History report was available for review and public comment was invited on the draft Purpose and Need Statement for the East Link EIS. FTA considered the mode analysis planning history and comments received during the scoping process before finalizing the East Link Purpose and Need. FTA, as lead federal agency, determined that planning level

decisions regarding mode (LRT) and corridor (I‐90) would be incorporated into the purpose and need, consistent with federal rules and guidance for linking the transportation planning and NEPA processes (see 23 CFR Sections 450.212 and 450.318 and Appendix A to Part 450 – Linking the Transportation Planning and NEPA Processes, Final Rule (Federal Register: February 14, 2007, Vol. 72, Number 30) and guidance found at: http://environment.fhwa.dot.gov/integ/related.asp

Response to comment ELFEIS011‐4 Please see response to comment # ELFEIS011‐2 above, regarding the use of the I‐ 90 center lane and the current court case regarding this issue. The R‐8A project is not used as mitigation for environmental impacts from the East Link Project. While the R‐8A project did not include high capacity transit (HCT), it was designed to accommodate HCT in the center roadway in the future. As described in Section 2.3.1 of the East Link Final EIS, the No Build Alternative included an option that considered completion of all stages of the R‐ 8A project, including operation of all HOV lanes provided by the R‐8A project. Please see response to comment #ELFEIS011‐3 above regarding the planning history leading to the light rail mode choice.

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Response to comment ELFEIS011‐5 Please see response to comment # ELFEIS011‐2 above.

Response to comment ELFEIS011‐6 The technical issues associated with the I‐90 floating bridge are discussed on pages 2‐22 and 2‐23 of the Final EIS, including the discussion and findings of load testing conducted on the bridge to evaluate the additional weight from light rail (which would not change the bridge's ability to remain safe during storm events). As described in these sections of the FEIS, the Washington State Legislature Joint Transportation Committee commissioned an independent review team (IRT) to evaluate several design issues related to installing and operating light rail on the I‐ 90 floating bridge, such as expansion joints, weight, stray currents, and bridge maintenance. The IRT concluded that all issues identified as potentially affecting feasibility can be addressed through project design measures. An IRT task force continues to advance work on design solutions to all the issues identified by the IRT and specific design measures will continue to be refined throughout the final design phase of the project. For example, Sound Transit will continue work on a track bridge prototype design and testing program, which will include construction and testing of a full scale track bridge prototype prior to installation on I‐90 at the existing expansion joints. If during operation the bridge is closed due to high wind, alternate bus service would be temporarily employed to provide service to light rail patrons.

Response to comment ELFEIS011‐7 Sound Transit completed a FHWA Interchange Justification Report in June 2011 and received a preliminary finding of engineering and operational acceptability. This report documented and included all of the ramp modifications included with Preferred Alternatives A1 and B2M. The letter providing the finding of engineering and operational acceptability is located in Appendix H1 of the Final EIS. Response to comment ELFEIS011‐8 The WSDOT is a co‐lead on the EIS and coordination occurred in the preliminary engineering and environmental review of the East Link alternatives. As part of this process, WSDOT and Sound Transit ensured the improvements included in the I‐ 405 Program were not prohibited with any of the potential East Link elevated crossings.

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Response to comment ELFEIS011‐9 Your comment has been noted. Please see Section 2.6 of the Final EIS for a discussion of costs and funding. The East Link Project is not applying for New Starts Funding. Table 3‐9 on page 3‐25 of the Final EIS shows the projected daily ridership for the preferred alternatives.

Letter ELFEIS015 Washington Trucking Associations Letter 15 was sent to FHWA official Dan Mathis as shown. A duplicate letter was also sent to FHWA official Victor Mendez. Page 1 Response to comment ELFEIS015‐1 Sound Transit’s ridership estimates are determined from the Sound Transit ridership patronage model. With the East Link project, transit ridership across Lake Washington is forecasted to increase by about 25 percent from the No‐Build Alternative. This is summarized in Section 3.1 and described in more detail in Sections 3.4 and 3.5 of the Final EIS.

Comparing future ridership forecasts for East Link to Central Link's initial ridership levels is not an appropriate comparison for several reasons. First, forecasts prepared for Central Link using Sound Transit’s incremental ridership model in the late 1990’s/early 2000’s was based on a system plan different than the current operating light rail system as well as a bus service integration plan that has not been fully implemented. Ridership forecasts for Central Link assumed a light rail line between the University District area (45th Street) and south of Sea‐ Tac Airport (South 200th Street). Currently, Central Link is operating between downtown Seattle and Sea‐Tac Airport. Other factors affecting Central Link ridership during its first two years of operation include an adjustment of people's behaviors to a new transportation mode (light rail); implementation of new fare system (the Orca card); and the economic recession and unemployment, which has depressed transit ridership during this period.. These issues primarily relate to the rate of ridership maturity on the Initial Segment of Central Link, not to the forecasting methodology in Sound Transit’s ridership model used for East Link (which has been reviewed by the Federal Transit Administration and two State Expert Review Panels). Overall, sound Transit's Central Link ridership has consistently increased since service implementation.

Response to comment ELFEIS015‐2 The reference to 2 percent per year is an annual growth rate not an overall total growth rate. Assuming an annual 2 percent growth rate, volumes would increase by approximately 30 percent from the existing (2007) conditions to year 2022.

Response to comment ELFEIS015‐3 Currently the majority of freight along this corridor travels outside the peak periods as shown in Exhibit 3‐28 of the Final EIS. That trend is expected to continue in the future as forecasted by the Puget Sound Regional Council (PSRC) (i.e., that the majority of daily freight movements will continue to occur outside the morning and afternoon peak periods).

Response to comment ELFEIS015‐4 The East Link project is forecasted to produce about 50,000 riders per day and of those riders approximately 10,000 would be new transit riders. This information is located on page 3‐6 of the Final EIS, under the bullet titled “Limited Transit Capacity and Connectivity.”

Response to comment ELFEIS015‐5 Chapter 1 of the Final EIS discusses the project’s purpose and need. As described in Section 1.2.3, the outer roadway is expected to reach its maximum vehicle capacity by 2015. Increased congestion in the No‐Build condition will further exacerbate bus service delays and limit mobility between Seattle and the Eastside communities creating a need for the project. As described in Section 3.5 of the Final EIS, the traffic operations on I‐90 during the peak periods would be similar or improved with the project. Page 2

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Letter ELFEIS016 Will Knedlik Response to comment ELFEIS016‐1 Page 1 The East Link Project does not propose to use any New Starts funding. The Final EIS analyzes the environmental impacts of the East Link project. The legal issues identified here and elsewhere in your comment letter and attachments, fall outside the scope of analysis required under the National Environmental Policy Act.

Response to comment ELFEIS016‐2 As discussed in the Executive Summary of the East Link Final EIS (ES.10, Areas of Controversy and Issues to be Resolved), in 2009 a lawsuit was filed by Eastside Transportation Association and others challenging the State of Washington’s constitutional authority to approve use of the I‐90 floating bridge center roadway for light rail transit. Petitioners sought a writ of mandamus barring the governor or secretary of transportation from “taking any action” pertaining to the conversion of lanes of I–90 for purposes of light rail. In April 2011, the Washington State Supreme Court denied petitioners’ request. Following the Supreme Court’s decision, the petitioner filed a similar challenge in Kittitas County Superior Court. The Kittitas lawsuit is pending.

Response to comment ELFEIS016‐3 Please see response to comment # ELFEIS016‐1 above.

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Response to comment ELFEIS016‐4 The purpose of the East Link project is to expand Sound Transit’s Link Light Rail system from Seattle to Mercer Island, Bellevue, and Redmond via I‐90 and to provide a reliable and efficient alternative for moving people throughout the region. Alternatives to light rail technology, including TSM and enhanced bus/BRT, were evaluated and eliminated from further review during the Sound Transit Long‐Range Planning and ST2 development process. The history of this planning process is documented in the report titled “East Corridor High Capacity Transit Mode Analysis History” (August 2006) and discussed in Section 1.3 of the Final EIS [Purpose and Need]). For example, as described on page 21 of the Mode Analysis History report, the 1993 the Regional Transit System Plan Final EIS evaluated eastside alternatives that included converting the I‐90 center roadway to a two‐way busway (the TSM alternative). During the scoping process for the East Link EIS in 2006, the Mode Analysis History report was available for review and public comment was invited on the draft Purpose and Need Statement for the East Link EIS. FTA considered the mode analysis planning history and comments received during the scoping process before finalizing the East Link Purpose and Need. FTA, as lead federal agency, determined that planning level decisions regarding mode (LRT) and corridor (I‐90) would be incorporated into the purpose and need, consistent with federal rules and guidance for linking the transportation planning and NEPA processes (see 23 CFR Sections 450.212 and 450.318 and Appendix A to Part 450 – Linking the Transportation Planning and NEPA Processes, Final Rule (Federal Register: February 14, 2007, Vol. 72, Number 30) and guidance found at: http://environment.fhwa.dot.gov/integ/related.asp

Response to comment ELFEIS016‐5 Your comment has been noted. Freight movement on I‐90 is discussed in Section 3.8 of the Final EIS. See also Response to comment ELFEIS008‐9 for a brief discussion of the differences between WSDOT’s 2006 analysis and the more recent analysis contained in the 2011 Final EIS. Response to comment ELFEIS016‐6 The East Link Project does not propose to use any New Starts funding. The “maximum bonding level” cited in your comment was contained in the 1994 Phase 1 System Plan, which was not approved by the voters in 1995. The Phase 1 System Plan was formally rescinded by the Sound Transit Board by Resolution No. 73 adopted May 1996. Sound Transit is subject to the statutory bonding limits contained in Chapter 81.112 RCW. Sound Transit is currently authorized to incur debt in an amount equal to 1 ½ percent of the value of taxable property within the service area, without securing voter approval for bonds. With the approval of 60 percent of the region’s voters, Sound Transit may incur aggregate indebtedness of up to 5 percent of the value of taxable property within the service area.

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Letter ELFEIS018 James W. MacIsaac Response to comment ELFEIS018‐1 Page 1 The purpose of the East Link project is to expand Sound Transit’s Link Light Rail system from Seattle to Mercer Island, Bellevue, and Redmond via I‐90 and to provide a reliable and efficient alternative for moving people throughout the region. Alternatives to light rail technology, including TSM and enhanced bus/BRT, were evaluated and eliminated from further review during the Sound Transit Long‐Range Planning and ST2 development process. The history of this planning process is documented in the report titled “East Corridor High Capacity Transit Mode Analysis History” (August 2006) and discussed in Section 1.3 of the Final EIS [Purpose and Need]). For example, as described on page 21 of the Mode Analysis History report, the 1993 the Regional Transit System Plan Final EIS evaluated eastside alternatives that included converting the I‐90 center roadway to a two‐way buswayM (the TS alternative). During the scoping process for the East Link EIS in 2006, the Mode Analysis History report was available for review and public comment was invited on the draft Purpose and Need Statement for the East Link EIS. FTA considered the mode analysis planning history and comments received during the scoping process before finalizing the East Link Purpose and Need. FTA, as lead federal agency, determined that planning level decisions regarding mode (LRT) and corridor (I‐90) would be incorporated into the purpose and need, consistent with federal rules and guidance for linking the transportation planning and NEPA processes (see 23 CFR Sections 450.212 and 450.318 and Appendix A to Part 450 – Linking the Transportation Planning and NEPA Processes, Final Rule (Federal Register: February 14, 2007, Vol. 72, Number 30) and guidance found at: http://environment.fhwa.dot.gov/integ/related.asp

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Response to comment ELFEIS018‐2 Please see Section 1.3 of the Final EIS for a brief description of the process in selecting light rail as the preferred technology, including the update and environmental review process for the Regional Transit Long‐ Range Plan that occurred between 2004 and 2006. The East Link Light Rail Transit Project identified in ST2 was approved by voters in November 2008. Sound Transit’s mission is to provide high capacity transit (both regional bus and rail service, including both light rail and commuter rail). Regional Express buses will continue to operate independent of and as a complement to light rail system as the light rail network expands. Sound Transit works closely with the PSRC and other transit agencies in the region (King County Metro, Pierce Transit and Community Transit) in planning regional transit. For a high‐capacity transit (HCT) system to maximize efficiency and ridership, it should operate in an exclusive right‐ of‐way. This is what was evaluated for Sound Transit’s Long‐Range Plan. Based on the analysis, the Sound Transit Board identified light rail as the mode for the East corridor.

Response to comment ELFEIS018‐3 Mode share information on both the I‐90 and SR 520 crossings of Lake Washington is provided in Table 3‐19 of Chapter 3 of the Final EIS. With the East Link Project, the transit mode share would increase by up to 25 percent across Lake Washington, while the HOV and SOV mode shares decrease. Transit transfer rate information for the No‐Build and Build conditions is provided in Table 4‐10 of Appendix H1. East Link would have a slightly less transit transfer rate than the No‐Build alternative as East Link is planned to connect with North Link to provide a one‐seat transit trip in the study area.

Sound Transit’s ST Express bus service, as well as King County’s transit routes, were analyzed for the level of service and operations. As shown in Table 3‐7 of Chapter 3 of the Final EIS, transit service along I‐90 operates about 50 percent on‐time for level of service (LOS) of either E or F. Future light rail service across I‐90 is expected to have a reliability of LOS A. Light Page 3 rail will also operate with more frequent headways during the peak and off‐peak periods of the day compared to Sound Transit's ST Express service and operate for more hours of the day. East Link will have an overall transit travel time savings (door‐to‐door) of about 9 minutes compared to buses. This information is provided in Section 3.4.

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Response to comment ELFEIS018‐4 Please see response to comments #ELFEIS018‐1 and 18‐2 above.

Response to comment ELFEIS018‐5 Your comment has been noted. Please see response to comments ELFEIS018‐1 and 18‐2 for a discussion why the TSM and BRT alternatives were not considered in the Final EIS. Please see Section 3.4.3.2 of the Final EIS for a discussion of bus level of service and operations.

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Letter ELFEIS019 William Popp Associates No comments Page 1 ‐ n/a ‐

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Response to comment ELFEIS019‐1 The intersection analysis was conducted according to the Transportation Methods and Assumptions Report included in Appendix A of Appendix H1 of the Final EIS. Within this report, the approaches for the travel demand forecasting and intersection analysis are described. This report and analysis was coordinated and reviewed with all cooperating agencies, including the City of Bellevue.

At the Bellevue Way SE and the South Bellevue Park and Ride intersection, Sound Transit received an existing conditions signal timing file from the City of Bellevue prior to the East Link DEIS. Since that time, the City of Bellevue has indicated they have adjusted signal operations along Bellevue Way SE. Because the existing conditions year of analysis is year 2007, no adjustments were performed to the intersection signal phasing. In the future year analysis, adjustments were performed based on the Transportation Methods and Assumptions Report and the intersection performance improved.

Response to comment ELFEIS019‐2 The transportation forecasts in Segment B (and along Bellevue Way SE) are predicted to increase in the future as stated in Table 3‐1. As the East Link project is a regional project spanning many jurisdictions, using the adopted regional PSRC model (with detailed transportation network refinements from the Bellevue‐Kirkland‐Redmond [BKR] model) is an appropriate travel demand forecasting approach. As part of the calibration process undertaken for the East Link project, base year data from the PSRC model was within 10 percent of existing volumes. Throughout the EIS process, the forecasts and general modeling approach was coordinated and reviewed with all cooperating agencies, including the City of Bellevue.

Response to comment ELFEIS019‐3 Section 3.6.3 of the Final EIS describes roadway improvements included in Alternative B2M to improve access and circulation surrounding the Page 3

South Bellevue Park and Ride. These roadway improvements would provide a similar intersection LOS with the project compared to the No‐ Build Alternative.

Response to comment ELFEIS019‐4 As described in Chapter 2 of the Final EIS and per the Sound Transit Board Resolution No.2011‐10, the selected alternative does not include an additional lane on Bellevue Way SE north of the South Bellevue Park and Ride. The Final EIS transportation study reports that another lane north of the South Bellevue Park and Ride is not necessary for satisfactory operation of this facility and traffic operations around the facility.

Response to comment ELFEIS019‐5 To follow through with Sound Transit Board’s Motion M2011‐62, the City of Bellevue and Sound Transit are working to develop an agreement that would provide for evaluating possible modifications to the project scope to address city goals of mitigating traffic, noise and visual impacts to the surrounding neighborhoods. The modifications must remain within the ST2 budget. The cost and effects of the possible modifications will be evaluated. If these changes are outside the range of impacts and alternatives evaluated in the Final EIS, then additional environmental review may be necessary.

Response to comment ELFEIS019‐6 The B7R option represents suggested revisions to the B7 alternative by the City of Bellevue, as described in Chapter 7 of the Final EIS. Traffic operations along Bellevue Way SE are influenced by a variety of sources. These factors include the park and ride but also the freeway operations along I‐90. Much of the traffic congestion experienced along Bellevue Way SE is created in part from the I‐90 mainline conditions. As both B7R and B2M include a park‐and‐ride along Bellevue Way, many transportation effects are similar although the South Bellevue Station with Alternative B2M is located on the east side of Bellevue Way SE while with B7R the station would be located within the Enatai neighborhood on the west side of Bellevue Way SE.

We rechecked the statement on page 7‐39 regarding satisfactory intersection operations with Alternative B7, and the statement is correct. This statement is based on the intersection operating at LOS D in year 2030 as indicated in Appendix D (page D‐5) of Appendix H1.

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Response to comment ELFEIS019‐7 The City of Bellevue’s B7R study did not suggest that the South Bellevue Park and Ride lot could be converted to park and wetland for the Mercer Slough area. WSDOT owns the South Bellevue Park and Ride Lot property. If the lot was closed under the B7R proposal, WSDOT may choose to use the site for other purposes and it would not automatically be available for wetland mitigation. Furthermore, preservation of existing wetlands is a preferred method of mitigation over creation of new wetlands, which is what would be required in this situation.

Response to comment ELFEIS019‐8 As stated, this description of neighborhood effects comes from the City of Bellevue’s Environmental Technical Memorandum that evaluated the B7R. Please see Sections 7.6.2.4 and 7.6.1 of the Final EIS for discussion summary of the City’s analysis of how the proposed B7R station and garage would change neighborhood views and alter traffic patterns, respectively. The station and garage would be located on a bluff in the Enatai neighborhood as shown in Exhibit 7‐2 of the Final EIS and would thereby increase activity in this neighborhood. The station and garage does not need to affect all elements of the neighborhood to have an effect on the character of the neighborhood.

Regarding traffic issues, the station is located within the Enatai neighborhood on the west side of Bellevue Way SE. An access road into the station is also located within Enatai and therefore provides a viable connection for park and ride users to potentially travel on within the Enatai neighborhood.

Response to comment ELFEIS019‐9 Sound Transit worked with the City of Bellevue and ARUP to provide base cost estimating information. The City presented their estimated costs and

cost saving considerations, as well as environmental effects of this combination to Sound Transit. This information is compared with the most closely represented fully studied Final EIS alternative, the B7 and Page 5

C9T Alternative– to the degree that information was available‐ in Section 7.6 of the Final EIS. As described on page 7‐37 of the Final EIS, the City’s cost estimates declare that B7R would cost 10 to 14 million dollars more than the B7 to C9T alternative.

Response to comment ELFEIS019‐10 See response to comments #ELFEIS019‐04 and ‐05 above.

Response to comment ELFEIS019‐11 Sound Transit worked with ARUP and provided them cost data as requested. Sound Transit reviewed the cost estimate and found that while many portions were comparable, some assumptions differed from Sound Transit’s light rail construction experience. However, Sound Transit used the cost estimates as presented for comparative purposes.

Response to comment ELFEIS019‐12 B7R would be more expensive than Alternative B7. A B7R/C14E combination, while being within the ST2 plan budget, would have lower than average ridership. Sound Transit’s study of the right of way “opportunities” are not fully possible along the former BNSF corridor since the project must incorporate future freight/commuter rail within the right of way. Please refer to comments #13, 14 and 15 of this letter for additional responses.

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Response to comment ELFEIS019‐13 A moving sidewalk was proposed by the City of Bellevue as part of Alternative C14E to connect with the Bellevue Transit Center to provide a link to other modes of transit. A sidewalk extension to the west beyond the Bellevue Transit Center would need to be completed by another agency or private interest. Extension of this sidewalk was not considered to the east along NE 6th Street as the NE 6th Street extension project was not considered a reasonable and foreseeable assumption by year 2030. A list of the background projects assumed in the transportation analysis is provided in Appendix A of Appendix H1 of the Final EIS. This list of background projects was reviewed and coordinated with the City of Bellevue and WSDOT.

Response to comment ELFEIS019‐14 Your comment has been noted. The B7R comparison provided in the Final EIS was based on the studies prepared by the City of Bellevue on this option.

The Noise Section 4.7 of the Final EIS has been updated since the Draft EIS to reflect the noise barriers as installed by the I‐405 South Bellevue project. The location of the cross‐over along the former BNSF corridor was also studied further in preparation of the Final EIS. The findings were that the cross‐over could only be shifted slightly due to profile and alignment constraints in where the cross‐over can feasibly be positioned. This adjustment is reflected in the current design and noise and vibration analysis in the Final EIS.

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Response to comment ELFEIS019‐15 Your support for B7R and C14E has been noted.

Response to comment ELFEIS019‐16 Responses to these concerns are addressed in the previous responses. If at any time, Sound Transit finds that the mitigation measures, which include refining design of the alignment, should result in environmental impacts not within the range of those already disclosed in the Final EIS, then Sound Transit would consider conducting additional environmental review as appropriate.

Response to comment ELFEIS019‐17 Responses to your concerns on the environmental review and cost estimating are addressed in responses to comments ELFEIS019‐01 through ‐14 above. Your support for the B7R/C9T and B7R/C14E has been noted.

Letter ELFEIS020 Coalition for Effective Transportation Alternatives Response to comment ELFEIS020‐1 Page 1 FHWA has granted the East Link project a preliminary engineering and operational acceptability approval through the Interchange Justification Report (IJR) Process, pending the EIS Record of Decision (ROD), which is included in the Final EIS as Appendix H to the Transportation Technical Report (Appendix H1 of the FEIS). The IJR process is not the FHWA ROD or an approval of the project, but rather documentation of the technical analysis to conclude if there are any engineering or operational concerns by FHWA on the proposal.

Response to comment ELFEIS020‐2 The purpose of the East Link project is to expand Sound Transit’s Link Light Rail system from Seattle to Mercer Island, Bellevue, and Redmond via I‐90 and to provide a reliable and efficient alternative for moving people throughout the region. Alternatives to light rail technology, including TSM and enhanced bus/BRT, were evaluated and eliminated from further review during the Sound Transit Long‐Range Planning and ST2 development process. The history of this planning process is documented in the report titled “East Corridor High Capacity Transit Mode Analysis History” (August 2006) and discussed in Section 1.3 of the Final EIS [Purpose and Need]). For example, as described on page 21 of the Mode Analysis History report, the 1993 the Regional Transit System Plan Final EIS evaluated eastside alternatives that included converting the I‐90 center roadway to a two‐way busway (the TSM alternative). During the scoping process for the EastS Link EI in 2006, the Mode Analysis History report was available for review and public comment was invited on the draft Purpose and Need Statement for the East Link EIS. FTA considered the mode analysis planning history and comments received during the scoping process before finalizing the East Link Purpose and Need. FTA, as lead federal agency, determined that planning level

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Response to comment ELFEIS020‐3 The East Link Project would close access to and from the reversible center roadway as indicated in Table 5‐3 of Appendix H1 of the Final EIS. The center roadway’s access locations limit the facility’s vehicle capacity and throughput as these access locations are either to or from a congested freeway mainline lane or arterial traffic signals. Because of these connections, the center roadway is predicted to operate under capacity in the future. East Link, which would overall carry up to 50,000 systemwide riders per day, provides bi‐directional light rail service in the center roadway.

Please see Response to comment ELFEIS008‐1 for a discussion of the additional lane capacity that will be provided on the I‐90 bridge by the “R‐8A” project.

Sound Transit ST Express bus services as well as King County routes were analyzed for the level of service and operations. As shown in Table 3‐7 of Chapter 3, transit service along I‐90 operates at about 50 percent on‐time for level of service (LOS) of either E or F. Future light rail service across I‐ 90 is expected to have a reliability of LOS A.

Sound Transit's Central Link ridership has consistently increased since service implementation, and it is now much closer to predicted forecasts. The economic recession and unemployment have depressed transit ridership during the first years of Central Link ridership.

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Response to comment ELFEIS020‐4 While the 2006 WSDOT I‐90 Center Roadway Study and the 2011 East Link Final EIS were conducted with appropriate transportation analysis methods, the two analyses use different modeling approaches. Refer to Appendix H of Appendix H1 of the East Link Final EIS for a description and overview of the recent I‐90 Transportation Studies, including the differences in modeling parameters and assumptions used in the 2006 Center Roadway Study. The East Link Project assumed a set of reasonable assumptions and methodologies that were based on decisions and agreements since the Center Roadway Study was published. Some of these differences include: the East Link analysis assuming tolling on SR 520; utilizing the latest release of the Puget Sound Regional Council's regional travel demand model at the time of analysis; incorporating Sound Transit's ridership transit forecasts into the PSRC forecasts; and assuming a different usage in the I‐90 HOV lanes. Additionally, the Center Roadway Study deferred some technical efforts that the East Link project conducted in greater detail. Therefore the East Link analysis better reflects the current understanding of future travel conditions along I‐90 when compared to the 2006 Center Roadway Study. Further, the Center Roadway Study confirmed the utility of the center roadway as an HCT facility with no center roadway access for vehicles. WSDOT is a co‐lead for the East Link Final EIS, and the transportation analysis provided in the 2011 Final EIS was reviewed and approved by WSDOT.

Response to comment ELFEIS020‐5 See response to Comment #ELFEIS020‐2 above.

Response to comment ELFEIS020‐6 East Link has a planned headway in the horizon year (year 2030) of trains every 7 minutes, although 4 minutes headways would be the maximum. Refer to Section 3.5 of the Final EIS for the I‐90 transportation analysis that concludes more people, with similar to faster travel times, are able to cross I‐90 with the East Link project compared to the No‐Build Page 4 alternative. The East Link project will carry up to 50,000 daily riders of which 10,000 of them are considered to be new transit riders.

Response to comment ELFEIS020‐7 Please refer to Table 7‐1, Chapter 7 of the Final EIS, Response to Common Comment CC1a regarding why BRT was not evaluated in the East Link EIS. Please also refer to response to comment #ELFEIS020‐2 above.

Response to comment ELFEIS020‐8 In comments on the Draft EIS and SDEIS, CETA requested that an enhanced bus system be analyzed as part of the No Build alternative. As discussed in Section 2.3.1 of the Final EIS, the “No Build Alternative includes a variety of project, funding packages, and proposals in the central Puget Sound region. The projects primarily consist of funded or committed roadway and transit actions by state, regional and local agencies combined with other projects that that are likely to be implemented based on approval and committed funding.” Since no plans have been developed for an enhanced bus system as suggested, it is not appropriate to include such a system in the No Build analysis. This is consistent with NEPA requirements.

As described in the response to comment ELFEIS020‐2 above, while an enhanced bus or BRT alternatives to light rail technology was not included in the “no‐build” alternative review in the FEIS, TSM and enhanced bus/BRT were evaluated during the Sound Transit Long‐Range Planning and ST2 development process. The history of this planning process is documented in the report titled “East Corridor High Capacity Transit Mode Analysis History” (August 2006) and discussed in Section 1.3 of the Final EIS [Purpose and Need]). For example, as described on page 21 of the Mode Analysis History report, the 1993 the Regional Transit System Plan Final EIS evaluated eastside alternatives that included converting the I‐90 center roadway to a two‐way busway (the TSM alternative). Please also refer to Table 7‐1, Chapter 7 of the Final EIS, Response to Common Comment CC1a regarding why BRT was not evaluated in the East Link EIS. For the extensive reasons discussed in this planning history of the project, these alternatives were not brought forward into the EIS process.

As part of the Interchange Justification Report (IJR) Process, the technical team of engineers and planners that evaluated the merits of the East Link IJR was provided the alternatives considered but rejected through Sound Transit’s long‐range planning process. This included a BRT/TSM alternative and is documented in Policy Point 2 (Alternatives) of the East Link IJR.

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No comments ‐ n/a ‐

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Response to comment ELFEIS020‐9 WSDOT’s Design Manual Chapter 550 includes the procedures and organization of the Interchange Justification Report (IJR) team. The East Link Project followed these steps in conducting the IJR process.

As part of the IJR Policy Points, it is considered appropriate to have a similar analysis conducted for the project’s EIS and IJR. Both of these documents rely on a similar analysis and methodology, therefore if the EIS and IJR are being conducted within a similar timeframe they are usually based on the same set of reasonable and acceptable assumptions.

Similar to responses to earlier comments, the 2006 WSDOT I‐90 Center Roadway Study and the 2011 East Link Final EIS were conducted with appropriate transportation methods. The two studies use different modeling approaches and methodologies. These are documented in Appendix H of Appendix H1. This Appendix provides a description and overview of the recent I‐90 transportation studies, including the differences in modeling parameters and assumptions used in the 2006 Center Roadway Study. The Center Roadway Study confirmed the utility of the center roadway as an HCT facility with no center roadway access for vehicles.

Response to comment ELFEIS020‐10 See response to Comment #ELFEIS020‐2 above. The project has complied with NEPA and other appropriate regulations.

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No comments ‐ n/a ‐

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Letter ELFEIS021 Alfred Cecil Response to comment ELFEIS021‐1 Page 1 The purpose of the East Link project is to expand Sound Transit’s Link Light Rail system from Seattle to Mercer Island, Bellevue, and Redmond via I‐90 and to provide a reliable and efficient alternative for moving people throughout the region. Alternatives to light rail technology, including TSM and enhanced bus/BRT, were evaluated and eliminated from further review during the Sound Transit Long‐Range Planning and ST2 development process. The history of this planning process is documented in the report titled “East Corridor High Capacity Transit Mode Analysis History” (August 2006) and discussed in Section 1.3 of the Final EIS [Purpose and Need]). For example, as described on page 21 of the Mode Analysis History report, the 1993 the Regional Transit System Plan Final EIS evaluated eastside alternatives that included converting the I‐90 center roadway to a two‐way busway (the TSM alternative). During the scoping process for the East Link EIS in 2006, the Mode Analysis History report was available for review and public comment was invited on the draft Purpose and Need Statement for the East Link EIS. FTA considered the mode analysis planning history and comments received during the scoping process before finalizing the East Link Purpose and Need. FTA, as lead federal agency, determined that planning level decisions regarding mode (LRT) and corridor (I‐90) would be incorporated into the purpose and need, consistent with federal rules and guidance for linking the transportation planning and NEPA processes (see 23 CFR Sections 450.212 and 450.318 and Appendix A to Part 450 – Linking the Transportation Planning and NEPA Processes, Final Rule (Federal Register: February 14, 2007, Vol. 72, Number 30) and guidance found at: http://environment.fhwa.dot.gov/integ/related.asp

The technical issues associated with the I‐90 floating bridge are discussed on pages 2‐22 and 2‐23 of the Final EIS, including the finding by the independent review team commissioned by the Washington State Legislature Joint Transportation Committee that “all issues identified as

potentially affecting feasibility can be addressed through proper design measures.” Response to comment ELFEIS021‐6 As described in Section 4.17 of the Final EIS, mitigation for parkland Response to comment ELFEIS021‐2 impacts would be through financial compensation or replacement Your comment has been noted. Costs to implement mitigation measures were property. Mitigation commitments will be implemented during final included as part of the cost estimates prepared for the Final EIS as described in design, construction, and/or operation of the East Link project. Section 2.6.2. Response to comment ELFEIS021‐7 Response to comment ELFEIS021‐3 Funding resources for the East Link Project (Seattle to Overlake Transit Please see page 6‐20 of Appendix H2 to the Final EIS for a detailed discussion of Center – Segments A through D) is described in Section 2.6.1 of the Final vibration impacts at the Winters House during operation of Preferred Alternative EIS. Depending on funding resources, the extensions beyond Overlake B2M. The operational vibration levels at this location are projected to be 76 VdB, Transit Center may have to be incorporated into future funding packages which would be below the FTA detailed impact criteria of 78 VdB for human which would require a public vote. annoyance and well below the 94 VdB criteria for structural damage. Response to comment ELFEIS021‐8 Response to comment ELFEIS021‐4 Section 4.7 and Appendix H2 of the Final EIS address wheel squeal and Please see Section 3.6.4.2 of the Final EIS for a discussion of Roadway and Parking provide the noise and vibration analysis and appropriate mitigation. The impacts during construction. The transportation analysis methodology and methodology for impact analysis is from the Transit Noise and Vibration assumptions, specifically the modeling approach for this project, is described in Impact Assessment Manual (Federal Transit Administration [FTA], revised detail in Appendix A of Appendix H1 of the Final EIS. In summary, as the East Link May 2006). These criteria are used for all federally funded high‐capacity project is a regional project spanning many jurisdictions, the adopted regional transit projects. Construction noise, parking facilities and maintenance PSRC model (with detailed transportation network refinements from the Bellevue‐ facilities would be required to meet the noise regulations of local Kirkland‐Redmond [BKR] model) was utilized for the travel demand forecasting. jurisdictions. Construction period impacts, that were determined using this model, are discussed in Section 3.6.4 of the Final EIS. Mitigation measures for the Preferred Alternative are also in Appendix I of the Final EIS and in Attachment C to this Record of Decision.

Response to comment ELFEIS021‐5 Mitigation details for temporary closure of the South Bellevue Park and Ride have not yet been identified, but will be during the final design process. The Section 6(f) analysis in the Final EIS considers replacement property of lands that have been funded for acquisition or improvement through Land Water Conservation Fund grants, such as the Mercer Slough Nature Park. Please see Section D.8 of Appendix D to the Final EIS for a discussion of Section 6(f) impacts. Page 2

Response to comment ELFEIS021‐9 The location of the crossover on Alternative B7 was evaluated during conceptual design and it was determined that the proposed location was the most appropriate because of topographical constraints and design criteria. The locations of all cross‐overs, including this one, have been reviewed by the designers to minimize potential noise exposure at residential properties, while accommodating the operational needs of the system.